Privacy Policy - Platform User

(Updated April 2024)

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 (the EULA) or as presented to you when you first use or install our Platform (as defined in the 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 (Mobile Platform) or online through our website (Web Platform), 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); and
  • Any other interactions with us, by phone or computer or otherwise, this policy will govern the processing of your personal data that we carry out.
 

Our Platform is 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. Authorised 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 Champion Health Ltd, , 6th Floor, 125 London Wall, London EC2Y 5AS, United Kingdom . We are the data controller who is responsible for your personal data (collectively referred to as, “we“, “us” or “our” in this policy).

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.

Our DPO’s contact details are:

  • Name or title of DPO:  Gary Hibberd
  • Email address: support@championhealth.co.uk
  • Postal address: Champion Health Ltd,  6th Floor, 125 London Wall, London EC2Y 5AS, United Kingdom
 

CONSENT

 

Before installation or access to the Platform, you will be asked to indicate your consent to our collection and processingof your personal data (where ‘consent’ has been identified as the appropriate lawful basis as described in this policy).


How you can withdraw consent

 

Once you provide consent for us to collect and process your personal data for specified processing activities (see online registration form) you may change your mind and withdraw consent at any time by visitn our Website Support Page or by emailing us (support@championhealth.co.uk) but that will not affect the lawfulness of any collection and processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information, but only where this is strictly required for insurance purposes or other legal compliance. We will delete any information that we do not strictly need to comply with our own legal obligations as we are required to by data protection laws. We shall not be able to remove any data that you provided that we have already fully anonymised 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)
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • App Data.
  • Marketing and Communications Data.
 

We will be collecting data related to information about your health, which is defined as being  ‘Special Category’ personal data by data protection laws.

We do not collect any information about criminal convictions and offences. Where we collect Special Categories of Personal Data about you, we will ask for your explicit consent to process this information. We will only ask for your consent again if the purpose of our processing changes.

We do not collect financial or transaction data where your employer or a family member or friend provides you with access to our Services.


In some instances, some of your details may be shared with a group of your colleagues if you choose to participate in certain features/programmes offering within the Platform.  For example, if you take part in the Champion Health  “Steps Challenge” or any other challenge/ feature that tracks and/or shares any of your details, you are consenting to your details being tracked in your version of the platform and for your details being shared with your group of colleagues who are also consenting to be part of that feature/ program at any point and if you no longer wish for your details to be shared, you may adjust your settings within your application by navigating to your Profile section with is accessed via the footer navigation  Once you adjust your settings, your consent will be deemed to have been withdrawn and your details will no longer be shared with your colleagues.


DESCRIPTION OF CATEGORIES OF PERSONAL DATA

 

Identity Data: first name, last name, username or similar identifier, age, gender.

Contact Data: email address 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 log-in information stored on your Device and any digital content that you upload into the Champion Health Platform (eg your profile photo)

Profile Data: includes your username and password, 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, 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 may collect, use and share aggregated data such as statistical or demographic data for the  purpose of providing your employer with an anonymised summary of the workforce wellbeing. Aggregated data could be derived from your personal data (including your Health Data) but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a 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.


We may also use anonymised data (including your Health Data) for research and scientific purposes in order to either try and improve the way we deliver our own services,


We will either rely on legitimate interests or explicit consent as a lawful basis for the anonymisation of your personal data.  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, or if you have provided explicit consent and then wish to withdraw your consent, then please contact us to let us know, please note however, that because of the way in which we anonymise and aggregate data, we won’t be able to tell which data is yours so we may not be able to remove this data from any reports or research that it has been used for prior to the date of you withdrawing your consent or opting out.  If you withdraw consent for us to use your health data we will also be unable to provide other Services to you.


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 our Platform, download, register or use our Platform for the first time, subscribe to any of our Services, search for our 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.


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:


Cookies

 

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

 

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.
  • Identity Data, Contact Data from your employer to verify your employment status with them.
  • Identity Data, Contact Data from an Authorised User to provide you with access to our Platform via the Friends and Family scheme.
 

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

Device

Performance of a contract with you.

To deliver our Services including the provision of in-App notifications

Identity

Contact

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

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 to you

To make recommendations to you about application and platform features which may interest you

To monitor trends so we can improve the platform and application functionality.

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Necessary for our legitimate interests where you have expressly opted in or indicated a request for these

To anonymise your personal data for research and scientific purposes so that we can improve the way we deliver our own services, or for other bodies and organisations to improve the ways in which they deal with and manage the health of their employees in the workplace.

Health Data (Special Category)

Consent

 

DISCLOSURES OF YOUR PERSONAL DATA

 

When you provide us with your personal data, we may only share your personal data with the third parties for the purposes set out in the table (above) Purposes For Which We Will Use Your Personal Data, and for the purposes outlined below:

  1. External Third Parties as set out in the Glossary.
  2. 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 of any kind.
  • 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

 

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

MARKETING

 

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


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 for use in the UK which give personal data the same protection it has in the UK (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.


EU REPRESENTATIVE

 

Our representative within the EU with respect to our obligations under European data protection law is Physiotools Oy incorporated and registered in Finland with company number 0491074-9 whose address is Kehräsaari B, 5th Floor, 33200 Tampere, Finland.  Email: data.protection@physiotools.com


DATA SECURITY

 

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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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


DATA RETENTION

 

Your Personal Data is retained only for the duration that you have an active account with Champion Health. Your personal data is securely deleted when;

  • You contact us to request an account closure
  • Your employer discontinues their commercial agreement with Champion Health
  • Your account has been inactive for more than twelve (12) Months and continues to remian inactive after being notified with 30 days notice that your account will be deleted.
 

YOUR LEGAL RIGHTS

 

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

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.  For further information see the paragraph below entitled ‘YOUR LEGAL RIGHTS’.

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

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 in September 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.


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.