Privacy Policy

2. In this notice

• How do we get your information
• What personal data we process and why
• Lawful basis for processing your personal data
• How long we keep your personal data
• Data sharing
• Do we use any data processors
• Your rights about this processing
• Transfers of personal data
• Further information

3. Personal Data

When you interact with The Happy Health Place Limited in relation to your relationship with us as a customer, you may provide us with, or we may obtain, personal data about you. This may include, but is not limited to:

As our customer:
• Contact details such as: name, business/work address, business/work telephone number, business/work and/or personal email address.
• Place of work or employment.
• Your business or company bank account or other payment details.

As an employee of our customers:
• Contact details such as: name, business/work and/or personal telephone number, business/work and/or personal email address.
• Your date of birth.
• Health data.

 

4. Where We Collect Your Data

The Happy Health Place Limited typically collect personal data about customers through the sales and marketing process, either directly from customers or sometimes from their employer. We may sometimes collect additional information from third parties including online business directories.

If you are providing us with details of your employees, they have a right to know and to be aware of what personal information we hold about them, how we collect it, how we use it and how we may share that information.

Please share this policy with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

5. Uses Made of your Personal Data

The tables below describe the main purposes for which we process your personal data, the categories of your information involved and our lawful basis for being able to do this.

Purpose	Personal Information Used	Lawful Basis
To negotiate with you to enter a contract as a customer with us	Name, business address, business email, business telephone, title	Contract
To communicate with you as one of our customers	Name, business address, business email, business telephone, title	Contract
To send you marketing communications	Name, business address, business email, business telephone, title	Consent & Legitimate Interest
To fulfil our obligations to you as one of our customers in relation to your contract with us	Name, business address, business email, business telephone, title, payment details, employee details	Contract
To fulfil our obligations to you as an employee of one of our customers	Name, business address, business telephone, business email address, date of birth	Legitimate Interest
To fulfil our obligations to you as an employee  of one of our customers	Health data	Legitimate Interest

 

6. Lawful Basis for Processing Your Personal Data

Depending on the processing activity, we rely on the following lawful basis for processing your personal data under the GDPR:
• Article 6(1)(a) where we have your consent to process your personal data.
• Article 6(1)(b) which relates to processing necessary for the performance of a contract.
• Article 6(1)(f) for the purposes of our legitimate interest.

For some of your personal information you will have a legal, contractual, or other, requirement or obligation to provide us with your personal information. If you do not provide us with the requested personal information, we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate our contract. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section 1.12 below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent, and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain services to you.

7. How Long We Keep Your Personal Data 

For information about how long we hold your personal data, see our retention schedule.

8. Disclosure Of Your Personal Data 

In some circumstances, such as under a court order, we are legally obliged to share information. We may also share information about you with third parties including government agencies and external auditors. For example, we may share information about you with HMRC for the purposes of financial reporting.

9. Do We Use Any Data Processors? 

Yes – a list of our current data processors can be found at Annex A.

10. International Transfers

The personal data collected by The Happy Health Place Limited is sometimes transferred to or stored in countries outside the United Kingdom.
If data is sent to any EU/EEA member states, the transfers are safeguarded by an adequacy decision. However, in some instances, data is sent to the USA.
When data is sent to the USA, we ensure the recipient business is signed up to the UK-U.S. Data Bridge, which acts as the transfer safeguard.
Where a USA business we transfer to is not signed up to the UK-U.S. Data Bridge, we will ensure that we use an International Data Transfer Agreement as a transfer safeguard.

11. Your Rights In Relation To This Processing

As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the Information Commissioner as the relevant supervisory authority.

For more information on your rights, please see ‘Your rights as an individual’.

Right of Access:

You have the right to obtain confirmation from The Happy Health Place Limited as to whether personal data concerning you are being processed and, where that is the case, access to that data.

Right to Rectification:

You have the right to oblige The Happy Health Place Limited to rectify inaccurate personal data concerning you. Considering the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.

Right to Erasure (Right to be Forgotten):

You have the right (under certain circumstances, but not all) to oblige The Happy Health Place Limited to erase personal data concerning you.

Right to Restriction of Processing:

You have the right (under certain circumstances, but not all) to oblige The Happy Health Place Limited to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.

Right to Data Portability:

You have the right (under certain circumstances, but not all) to oblige The Happy Health Place Limited to provide you with the personal data about you which you have provided to The Happy Health Place Limited in a structured, commonly used, and machine-readable format.
You also have a right to oblige The Happy Health Place Limited to transmit those data to another controller.

Right to Withdraw Consent:

If the lawful basis for processing is consent, you have the right to withdraw that consent.

Right to Object to Direct Marketing:

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.

Rights in Relation to Automated Decision-Making and Profiling:

The Happy Health Place Limited does not perform any automated decision-making based on personal data that produces legal effects or similarly affects you.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them, and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

 

If you wish to exercise any of your rights concerning your personal data, you should contact The Happy Health Place Limited’s Data Protection Manager at the address shown above. If you are not satisfied with the response you receive, you have the right to lodge a complaint with the supervisory authority. In the United Kingdom this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF Telephone: 0303 123 1113
Email: casework@ico.org.uk
Web: https://ico.org.uk/for-the-public/

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by emailing dataprotectionmanager@healthappy.co.uk