Privacy Policy - General

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

 

Key terms

 

It would be helpful to start by explaining some key terms used in this policy:

 

We, us, ourChampion Health Ltd a company registered in England and Wales with company registration number 11456257 of with registered address at 10 Kenwood Park Road, Sheffield, United Kingdom, S7 1NF
Our data protection officer
Personal dataAny information relating to an identified or identifiable individual
Special category personal data
  • Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
  • Genetic and biometric data (when processed to uniquely identify an individual)
  • Data concerning health, sex life or sexual orientation
Data subjectThe individual who the personal data relates to

 

What personal data we collect about you and how we use it

 

Under data protection law, we can only use your personal data if we have a proper reason, eg:

 

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

 

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

 

We process the personal data of various groups of individuals. We have listed these groups below as headings with a table underneath each heading providing more details as to what data we collect and why.

 

To find out more about what personal data we process, what we do with it and why we need it, please look for the group heading you belong to and then review the table contained underneath the relevant heading.

 

Our referrers and contributors 

 

What personal data we collectReason(s) for collecting this personal dataLawful basis relied on under the UK GDPR
Title, name, email, address, address, telephone number, bank details
  • To communicate with you generally and in relation to any contribution(s) or referral(s) you make.
  • To enable you to be assessed as a potential contributor or referrer and, once accepted, to enable you to be enrolled as a contributor or referrer
  • To set you up on our systems to enable you to be rewarded for your referral(s) or contribution(s)
  • To track your referrals and contributions
Contractual – to enable and fulfil our contract with you

 

Those who apply for a job with us

 

What personal data we collectReason(s) for collecting this personal dataLawful basis relied on under the UK GDPR
Title, name, email, address, address, telephone number, work history, health information, ID documentation and any details provided on these documents, any other personal data you provide
  • To communicate with you regarding your job application
  • To process and assess your application
  • To confirm your identity and assess your right to work
  • Our lawful basis for most of your data we collect is our legitimate interests – our legitimate interest of processing your job application and assessing you as a candidate
  • In relation to data collected to complete the right to work checks, our lawful basis is legal obligation
  • In relation to any special category data you provide, we rely on your consent to process this data

 

Those who are employed by us or engaged as a contractor or freelancer

 

What personal data we collectReason(s) for collecting this personal dataLawful basis relied on under the UK GDPR
Title, name, email, address, address, telephone number, work history, date of birth, health information, ID documentation and details, any other personal data you provide
  • To communicate with you
  • To enable you to work for us
  • To pay you
  • To pay tax
  • To confirm your identity and assess your right to work
  • Our lawful basis for most of your data we collect contractual
  • In relation to data collected to complete the right to work checks and to pay tax, our lawful basis is legal obligation
  • In relation to any special category data you provide, we rely on your consent to process this data

 

Those who contact us 

 

What personal data we collectReason(s) for collecting this personal dataLawful basis relied on under the UK GDPR
Title, name, email, address, telephone number, any other personal data you provide
  • To communicate with you
  • To enable us to resolve any query you might have
Our lawful basis is legitimate interests. Our legitimate interests are responding to your query.

 

Those interested in learning more about our products and services 

 

What personal data we collectReason(s) for collecting this personal dataLawful basis relied on under the UK GDPR
Title, name, email, address, telephone number, any other personal data you provide
  • To communicate with you
  • To enable us to provide more details on our products and services
Our lawful basis is legitimate interests. Our legitimate interests are marketing and promoting our products and services

 

Those who enter any of our competitions or giveaways and the winners of any of our competitions and giveaways

 

What personal data we collectReason(s) for collecting this personal dataLawful basis relied on under the UK GDPR
Title, name, email, address, date of birth, telephone number, any other personal data you provide
  • To communicate with you regarding the competition or giveaway
  • To enter you into the competition or giveaway
  • To facilitate the running of the competition or giveaway
  • To verify your identity and/or your eligibility to enter the competition or giveaway
Our lawful basis is legitimate interests. Our legitimate interests are marketing and promoting our products and services

If you do not provide personal data we ask for, it may delay or prevent us from providing services to you (in the case of prospective customers), processing your application or job offer (in the case of prospective employees) and answering your query (in the case of those contacting us).

 

 

How and why we use your personal data—Special category personal data

 

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. This includes:

 

  • personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
  • genetic data
  • biometric data (when used to uniquely identify an individual)
  • data concerning health, sex life or sexual orientation.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

 

  • we have your explicit consent
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

 

How your personal data is collected

 

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

 

  • from publicly accessible sources, eg Companies House or HM Land Registry;
  • credit reference agencies
  • customer due diligence providers
  • from a third party with your consent
  • from cookies on our website—for more information on our use of cookies (please see our cookie policy below), via our IT systems, eg;
  • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

 

How and why we use your personal data—sharing

 

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

 

Who we share your personal data with

 

We routinely share personal data with:

 

  • third parties we use to help us run our business, eg marketing agencies or website hosts
  • third parties approved by you, eg social media sites you choose to contact us through or third party payment providers
  • credit reference agencies
  • our insurers and brokers
  • our banks

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

 

We or the third parties mentioned above occasionally also share personal data with:

 

  • our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

 

Who we share your personal data with—further information

 

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

 

Where your personal data is held

 

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

 

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

 

How long your personal data will be kept

 

We will not keep your personal data for longer than we need it for the purpose for which it is used.

 

Different retention periods apply for different types of personal data. Further details on this are available by contacting us (see ‘How to contact us’ below).

 

Transferring your personal data out of the UK and EEA

 

Countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

 

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

 

We will transfer your personal data to our service providers located outside the UK.

 

As we are based in the UK we will also transfer your personal data from the EEA to the UK.

 

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

 

  • in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here
  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
  • a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

 

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

 

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

 

Transferring your personal data out of the UK and EEA—further information

 

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

 

Your rights

 

You have the following rights, which you can exercise free of charge:

 

AccessThe right to be provided with a copy of your personal data
RectificationThe right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)The right to require us to delete your personal data—in certain situations
Restriction of processingThe right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portabilityThe right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to automated individual decision makingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by [insert details as relevant depending on consents]

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

 

If you would like to exercise any of those rights, please:

 

  • email, call or write to us—see below: ‘How to contact us’;
  • provide enough information to identify yourself [(eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you; and
  • let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal data secure

 

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

 

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

How to complain

 

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

 

You also have the right to lodge a complaint with:

 

  • the Information Commissioner in the UK
  • a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

 

For a list of EEA data protection supervisory authorities and their contact details see here.

 

Changes to this privacy policy

 

This privacy notice was published on May 2021 and last updated on June 2022.

 

We may change this privacy notice from time to time—when we do we will inform you via our website and/or other means of contact such as email.

 

How to contact us

 

Individuals in the UK

 

You can contact us and/or our Data Protection Officer by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

 

Our contact details are shown below:

 

Our contact details:Our Data Protection Officer’s contact details:

Email:

support@championhealth.co.uk

Postal address:

10 Kenwood Park Road, Sheffield, S7 1NF

Rosalind Watchorn

Email:

ros.watchorn@championhealth.co.uk

Postal address:

23, Kenwood Park Road, Sheffield, S7 1NF


Privacy Policy - User

Champion Health User Privacy Policy


(Updated April 2022)


Champion Health is committed to protecting your personal data and respecting your privacy.


  • PLATFORM INTRODUCTION


Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read that information.

This policy (together with our end-user license agreement as set out at www.championhealth.co.uk/eula or as presented to you when you first use or install any of our Platform (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:


  • All versions of our Platform, whether available whether made available to you as an app on your phone or online through our website “web platform” (Platform Site) or the relevant application market on your device, once you have downloaded or streamed a copy of the Platform onto your personal computer, mobile telephone or handheld or other suitable electronic device (Device);
  • Any of the services accessible through the Platform or the Platform Site via any Device (Services) that are available on the Platform Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us as part of our Services provided via the Platform; and
  • No matter how you interact with us, by phone or computer, this policy will govern the processing of your personal data that we carry out and where we do something specific to either mobile or web (depending on what versions of our Platform you use) then we will make it clear where that kind of processing only applies to either our mobile application, or our web application versions of the Platform.


The Platform are not intended for use by, or for the purpose of the collection of any personal data relating to, children (under the age of 16 years) and we do not knowingly collect data relating to children. Authorized Users (Employees) may assign and revoke up to 3 (three) access licenses to friends or family members (over the age of 16 years).


Please read the following carefully to understand our practices regarding your personal data and how we will treat it.


WHO WE ARE


Champion Health Ltd is a company registered in England and Wales with company registration number 11456257 of with registered address at 10 Kenwood Park Road, Sheffield, United Kingdom, S7 1NF. We are the controller who is responsible for your personal data (collectively referred to as, “we“, “us” or “our” in this policy).


Our contact details


  • Postal address: 10 Kenwood Park Road, Sheffield, S7 1NF


We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.


DPO contact details


Our DPO’s contact details are:


  • Name or title of DPO: Rosalind Watchorn
  • Email address: ros.watchorn@championhealth.co.uk
  • Postal address: 23, Kenwood Park Road, Sheffield, S7 1NF


CONSENT


Before installation or access to the Platform, you will be asked to indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.


How you can withdraw consent


Once you provide consent by acknowledging your agreement to our terms of service and data processing (see online registration form) you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information only where this strictly required for insurance purposes or other legal compliance, but we will delete anything we don’t strictly need to comply with our own legal obligations as we are required to by the GDPR. We won’t be able to remove any data you provided that we have fully anonymized as part of an Aggregated data set (which we describe below) that doesn’t reveal any individual’s identity.


THE DATA WE COLLECT ABOUT YOU


We may collect, use, store and transfer different kinds of personal data about you as follows:


  • Identity Data.
  • Contact Data.
  • Health Data (Special Category)
  • Financial Data.
  • Transaction Data.
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • App Data.
  • Marketing and Communications Data.


We will be collecting Special Categories of Personal Data about you (the definition of Special Categories includes 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).

If you use our Services then you will be providing us with Special Category of personal data, and because this may be provided via a free-text response by email, online contact form or over the phone, then by providing this information you are deemed to consent to our processing of that data in accordance with this policy. We do not collect any information about criminal convictions and offences. We will ask for your consent when you first use or install the Platform and thereafter we will only ask for your consent again if the purpose of our processing changes.


We only collect financial and transaction data if you pay us directly for our Services. We do not collect financial or transaction data where your employer or a family member or friend provides you with access to our Services.


DESCRIPTION OF CATEGORIES OF PERSONAL DATA


Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.


Contact Data: billing address, delivery address, email address and telephone numbers.


Financial Data: bank account and payment card details.


Transaction Data: includes details about payments to and from you and details of in-Platform purchases.


Health Data: includes information about your health and wellbeing.  This includes; lifestyle health related behaviors (nutritional / hydration intake, alcohol consumption, smoking, physical activity, sleep), physical health (Musculoskeletal conditions), Mental Health (stress, anxiety, depression)


Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.


Content Data: includes information stored on your Device, including login information, photos, videos or other digital content.


Profile Data: includes your username and password, in-Platform purchase history, your interests, preferences, feedback and survey responses.


Usage Data: includes details of your use of any of our Platform or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.


Marketing and Communications Data: includes your preferences in receiving marketing communications from us.


App Data: includes whether you are accessing the Platform through a mobile application.


AGGREGATED DATA AND ANONYMISATION


We also create, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data as described above, which includes your Health Data (Special Category), but is not considered personal data in law as this data will not directly or indirectly reveal your identity. This data falls outside of the scope of the GDPR and the UK Data Protection laws because it can’t be linked back to you. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. 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.


This policy doesn’t necessarily need to describe what we do with aggregated data, the GDPR says this kind of data falls outside its scope because you can no longer be identified from it, but we still want to tell you about what we plan to do with this data anyway.


We will use aggregated or anonymized data for research and scientific purposes in order to either try and improve the way we deliver our own services, or for other bodies and organizations to improve the ways in which they deal with and manage the health of their employees in the workplace. We also want to work with research groups and universities and use this data, in combination with other data sets, to help us and those third-party researchers understand health and wellbeing so that together we can try to understand the root cause and impact it has on people’s health. We might work with other people or companies for the same purposes from time to time, and we will do our best to tell you all about it on our website, or as part of our newsletter.


If you really do not want us or anyone else to use your data in this way, even though no one will be able to tell that you are the source of that data, then please contact us to let us know before you use our Platform or any of our Services. Because of the way in which we anonymize and aggregate data, we won’t be able to tell which data is yours if you decide you want to try to “opt-out” of this in the future, and if you do decline this processing of non-personal data then we might not be able to provide parts of our Services to you at all.


HOW IS YOUR PERSONAL DATA COLLECTED?


We will collect and process the following data about you:


Information you give us. This is information (including Identity, Contact, Health, Financial, and Marketing and Communications Data) you give to us by filling in forms whilst using our Platform, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Platform Site, download, register or use an Platform for the first time, subscribe to any of our Services, search for an Platform or Service, share data via an App’s social media functions, enter a competition, promotion or survey and when you report a problem with any of the Platform, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.


Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Platform we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy below for further details.


Information we receive from other sources including third parties and publicly available

 sources. We will receive personal data about you from various third parties and public sources as set out below:


  • Device Data from analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Inc based in the United States of America, GoCardless and Xero.
  • Identity Data, Contact Data, Health Data (Special Category), Financial Data, Transaction Data, Device Data, Content Data, Profile Data, Usage Data, App Data, Marketing and Communications Data from our third-party IT services providers or mobile application marketplaces who manage and run our Platform and the Services under our strict instructions and not for their own purposes.


Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.


HOW WE USE YOUR PERSONAL DATA


We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:


  • Where you have consented before the processing;
  • Where we need to perform a contract we are about to enter or have entered with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • Where we need to comply with a legal or regulatory obligation; and
  • To protect your vital interests where you are unable to give consent.


When we collect personally identifiable information through our digital platforms and website we will use the information in the way described above and we will make it clear what we intend to do with it. 


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA


Purpose/activity  Type of data  Lawful basis for processing 
To install the Platform and register you as a new Platform user

Identity

Contact

Financial

Device

Performance of a contract with you.
To deliver our Services including the provision of in-App notifications

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Health Data (Special Category)

Your consent (where we collect information about your state of health and wellbeing (Special Category))

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

Where necessary to protect your vital interests where you cannot give consent.

To manage our relationship with you including notifying you of changes to the Platform or any Services

Identity

Contact

Financial

Profile

Marketing and Communications

Performance of a contract with you.

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this Platform including troubleshooting, data analysis and system testing

Identity

Contact

Device

Health Data (Special Category)

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Consent

Necessary for our legitimate interests where you have expressly opted in or indicated a request for these (to develop our products/Services and grow our business)


COOKIES


We use cookies and other tracking technologies such as pixels to distinguish you from other users of our Platform, the Platform Site, the distribution platform (relevant appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the Platform or browse any of Our Sites and also allows us to improve the Platform and Our Sites. For detailed information on the cookies we use and the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy below.


Cookie Name Purpose  
__utma This cookie is used to monitor the number of times a visitor has been to the site related to the cookie, when they first visited the site, and when they were last on the site. Google Analytics uses the information from this cookie to calculate things like Days and Visits to purchase. More information
__utmb
__utmc
These two cookies work together to establish how long a visit has taken. b signals when a user enters the site and c signals when a user leaves. More information
__utmt A cookie used to throttle the request rate for the service, limiting the collection of data on high traffic sites. More information
__utmz This cookie captures how a visitor accessed the site including: which search engine was used, what link was clicked on, what keywords were used and geographical location. More information
Facebook Pixel A cookie issued to monitor traffic directed to our website from Facebook. This is used to provide relevant feedback to the user based on the content in which they have shown interest in. It is also used to gauge the effectiveness of our digital marketing campaigns. A user can opt out on the Facebook site. More Information


DISCLOSURES OF YOUR PERSONAL DATA


When you provide us with your personal data, we may share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:


  1. External Third Parties as set out in the Glossary.
  2. Specific third parties such as Stripe, Inc, GoCardless and Xero.
  3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.


Who we WILL NOT share your Health Data (Special Category) with:


  • Your employer or the group or organization to which you belong
  • Third party marketing providers or databases
  • Anyone outside of our business, unless and until we have made sure that you can’t be identified from the data we create (except as expressly set out in this policy). For more information on how this data is used after it is no longer “personal data” see the section on “AGGREGATED DATA” above.


FRIENDS & FAMILY ACCESS


  • Authorized Users (Employees) may assign and revoke up to 3 (three) access licenses to friends or family members (over the age of 16 years).
  • No anonymized and aggregated health data will be reported to businesses or organizations from friends or family user groups.


MARKETING


We will only send you direct marketing communications by email and only then if we have your approval at the point of registration for access to our digital platforms or when requesting information through our website. We will ask you to opt-in to receiving such marketing communications before we send anything to you. You have the right to opt-out of receiving marketing from us at any time using the unsubscribe link in our emails.


We do not  share your personal data with any third party for marketing purposes.


We never send you marketing based on your Health Data, and we will never share your Health Data with third parties unless you can’t be linked to that information (so that it is no longer personal data).


INTERNATIONAL TRANSFERS


We may transfer your personal information outside the United Kingdom (UK) and European Economic Area (EEA). Whenever we transfer your personal data out of the EEA or UK to a country that has not been deemed to provide an adequate level of protection for personal data by the European Commission, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the European Commission which give personal data the same protection it has in Europe. These are called the Standard Contractual Clauses.

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


DATA SECURITY


All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone else.


Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. Data is secured using a Next Generation firewall and hosted on a secure web hosting platform. Systems are penetration tested annually (scheduled) and Cyber Essentials certified. Systems are monitored and patched regularly ensuring security risks are mitigated.


We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.


DATA RETENTION


Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.


By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.


In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


In the event that you do not use the Platform for a period of twenty years then we will treat the account as expired and your personal data may be deleted.


YOUR LEGAL RIGHTS


Under certain circumstances you have the following rights under data protection laws in relation to your personal data.


  • Your rights allow you to request; access to your personal data., correction of your personal data, erasure of your personal data, restriction of processing your personal data, transfer or your personal data, withdrawal of your consent and; object to processing of your personal data.


You also have the right to ask us not to continue to process your personal data for marketing purposes.


You can exercise any of these rights at any time by contacting us at support@championhealth.co.uk


How you can withdraw consent


Once you provide consent by acknowledging your agreement to our terms of service and data processing (see online registration form) you may change your mind and withdraw consent at any time by contacting us (support@championhealth.co.uk) but that will not affect the lawfulness of any processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information only where this strictly required for insurance purposes or other legal compliance, but we will delete anything we don’t strictly need to comply with our own legal obligations as we are required to by the GDPR. We won’t be able to remove any data you provided that we have fully anonymized as part of an Aggregated data set (which we describe below) that doesn’t reveal any individual’s identity.


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or another competent supervisory authority of an EU member state if the Platform is downloaded outside the UK and you are not a UK citizen.


Changes to the privacy policy and your duty to inform us of changes


We keep our privacy policy under regular review.


This version was last updated 05/04/2022 It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email when you next start the Platform or log onto one of the Platform Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.


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 our relationship with you.


Third party links


Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data and Identity Data. Please check these policies before you submit any personal data to these websites or use these services.


GLOSSARY


1. LAWFUL BASIS


Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.


Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


Protecting your vital interests means processing your data where your vital interests are at stake, such as in an emergency situation, where we would consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data pursuant to this justification.


2. THIRD PARTIES


2.(A) EXTERNAL THIRD PARTIES


Service providers acting as processors based in the United Kingdom who provide IT and system administration services including mobile application marketplaces and mobile operating system.


Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.


Delivery services who we instruct in order to deliver our products and services to you who will be based in the United Kingdom where this is required in order to actually carry out and deliver your order.


3. YOUR LEGAL RIGHTS


You have the right to:


  • Request access to your personal data (commonly known as a “data subject access request”). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • (a) if you want us to establish the data’s accuracy;
    • (b) where our use of the data is unlawful but you do not want us to erase it;
    • (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      • Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.