Privacy Policy

THE HAPPY HEALTH PLACE LTD, T/A HEALTHAPPY
WEBSITE AND APP PRIVACY POLICY
1.            INTRODUCTION
1.1         The Happy Health Place Ltd (Company) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our app or website (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.
1.2         This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of our app and website.
1.3         The app and website are not intended for children and we do not knowingly collect data relating to children.
1.4         It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
1.5         This policy and any additional terms of use incorporated by reference into our end user licence agreement applies to your use of:
1.5.1         the Healthappy mobile application software once you have downloaded or streamed a copy of the app onto your mobile telephone or handheld device; and
1.5.2         the site under the domain name and associated sub-domain of https://healthappy.co.uk/  operated by the Company.
2.            Controller
2.1         The Company is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).
2.2         If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out in clause 18 below.
3.            AppLICATION
3.1         Before installation of our app, please indicate your consent to installation of the app and our processing of your personal data (including your name, contact details, financial and device information).
3.2         How you can withdraw consent. Once you provide consent, you may change your mind and withdraw consent at any time by contacting us using the contact information in clause 18, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
4.            Third-party links
This website and our app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy policy of every website you visit.
5.            The data we collect about you
5.1         Personal data, or personal information, means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data).
5.2         We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in the table set out in the Schedule.
5.3         We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
5.4         Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5.5         We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal 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 specific website or app 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.
5.6         We do not generally collect any Special Categories of Personal Data about you (this 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), but we do collect data about your ethnicity. Nor do we collect any information about criminal convictions and offences.
5.7         If you fail to provide personal data:
5.7.1         Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).  In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6.            How is your personal data collected?
We use different methods to collect data from and about you including through:
6.1         Direct interactions.  This is information (including identity, contact, financial, and marketing and communications data) you consent to giving us about you by filling in forms on our website or app, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the website or app, download or register an app, subscribe to any of our services, search for an app or service, make an in-app purchase, share data via an app’s social media functions, enter a competition, promotion or survey and when you report a problem with an app, our services, or our website. If you contact us, we will keep a record of that correspondence.
6.2         Automated technologies or interactions.  As you interact with our website or app, we will automatically collect technical data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites or apps employing our cookies. Please see clause 10 below for further details.
6.3         Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
6.3.1         Technical data from the following parties:
(a)       analytics providers such as Google;
(b)       advertising networks; and
(c)       search information providers.
6.3.2         Contact, financial and transaction data from providers of technical, payment and delivery services.
6.3.3         Identity and contact data from data brokers or aggregators.
6.3.4         Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
6.4         Information we collect about you and your device. Each time you visit our website or use our app we will automatically collect personal data including device, content and usage data. We collect this data using cookies and other similar technologies.
6.5         Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location data in your settings.
6.6         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.
7.            How we use your personal data
7.1         The main purposes/activities for which we process your personal data are summarised in the table in the Schedule and include the following:
7.1.1         To register you as a new customer.
7.1.2         To provide you with our products and services.
7.1.3         To manage payments, fees and charges and collect and recover money owed to us.
7.1.4         To communicate with you and manage our relationship, which will include:
(a)       Providing you with updates you have requested;
(b)       Notifying you about changes to our terms or privacy policy;
(c)       Asking you to leave a review or take a survey.
7.1.5         To enable you to partake in a prize draw, competition or complete a survey.
7.1.6         To administer and protect our business, our app and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
7.1.7         To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
7.1.8         To use data analytics to improve our website, app, products or services, marketing, customer relationships and experiences.
7.1.9         To make suggestions and recommendations to you about products or services that may be of interest to you.
7.2         We may need to share some of the categories of personal information with other parties as set out in the Schedule. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7.3         We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7.4         Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7.5         Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us in writing, by email or telephone using the details shown in paragraph 18 below.
8.            Marketing & Promotional offers
8.1         We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
8.2         We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which products, services and offers may be relevant for you (we call this marketing).
8.3         You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case you have not opted out of receiving that marketing.
9.            Opting out
9.1         We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
9.2         You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time using the contact details in clause 18.
9.3         Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.
10.         Cookies
10.1       Our website and app use cookies to distinguish you from other users of our website or app. This helps us to provide you with a good experience when you browse our website or use our app and also allows us to improve the app and our site.
10.2       A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer’s or device’s hard drive.
10.3       We use Google Analytics cookies to identify which pages are being used on our website. Google Analytics is a web analytics service provided by Google LLC who are based in the USA. As a result, information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the USA. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
10.4       Google Analytics helps us analyse data about web page traffic and improve our website to tailor it to the needs of our customers. This information is only processed in a way that does not directly identify anyone. We do not make, and do not allow Google Analytics to make, any attempt to find out the identities of those visiting our website. We only use this information for statistical analysis purposes. The information collected is classed as personal data because Google assigns a unique identifier to each visitor. “_ga” is the main cookie used by Google Analytics, this allow us to distinguish between one user from another. For more information read Google’s overview of privacy and safeguarding data.
10.5       Overall, cookies help us provide you with a better website experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
10.6       You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
10.7       Please note that third parties (including for example, advertising networks and social media providers) may also use cookies, over which we have no control. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.
10.8       All cookies will expire after 24 months from your last visit to our website.
11.         Change of purpose
11.1       We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
11.2       If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
11.3       Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
12.         Disclosures of your personal data
12.1       As outlined in the table in the Schedule, we may need to share your personal data with third parties, examples of which are listed below:
12.1.1      Service providers who provide IT and system administration services.
12.1.2      Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
12.1.3      HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
12.2       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.
12.3       We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
13.         International transfers of information
13.1       Apart from our use of Google Analytics (as described above) we do not normally transfer your personal data outside the UK.
13.2       Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
13.2.1      We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
13.2.2      Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
13.3       Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
14.         Data security
14.1       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.
14.2       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.
14.3       Where we have given you (or where you have chosen) a password that enables you to access certain parts of our app or website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
15.         Data retention
15.1       We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
15.2       To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
15.3       In some circumstances we will anonymise 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.
16.         Your legal rights in connection with personal data
16.1       Under certain circumstances, by law you have the right to:
16.1.1      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.
16.1.2      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.
16.1.3      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.
16.1.4      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.
16.1.5      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.
(d)       You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
16.1.6      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.
16.1.7      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.
16.2       If you wish to exercise any of the rights set out above, please contact us.
16.3       No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
16.4       What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.
16.5       Time limit to respond. We try to respond to all legitimate requests within one month.  Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.
17.         Changes to the privacy policy and your duty to inform us of changes
17.1       We keep our privacy policy under regular review.  This version was last updated on [DATE].  It may change and if it does, these changes will be posted on this page or in our app.
17.2       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 your relationship with us.
18.         contacts & Complaints
18.1       If you have any questions about this privacy policy or our privacy practices, please contact us via our contact form, or at the following email address [email protected]
18.2       You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
  • About the information we collect and hold
The information we collect
How we collect the information
Why we collect the information
How we use and may share the information
Identity data including first name, maiden name, last name or similar identifier, marital status, title, date of birth, gender and employment information.
From you
To enter into/perform our contract with you
Legitimate interest: to ensure that you are properly identified as a customer and that we are able to perform our obligations under our contract with you on an on-going basis
Where we need to comply with a legal or regulatory obligation
To enter into/perform our contract with you
Contact data, including addresses, email addresses and telephone numbers.
From you
From selected third parties such as data brokers or aggregators
From publicly available sources such as Companies House and the Electoral Register
To enter into/perform our contract with you
Legitimate interest: to ensure that you are properly identified as a customer and that we are able to perform our obligations under our contract with you on an on-going basis
To enter into/perform our contract with you
Financial data including bank account details, billing information, payment card details and credit history, information to enable us to undertake credit or other financial checks on you
From you
From selected third parties including credit reference agencies
To enter into/perform our contract with you
Legitimate interest: to establish your ability to make payments to us under our contract with you, and to obtain such payments
To enter into/perform our contract with you
To establish your ability to make payments to us and to obtain such payments
Contract and transaction data including details about payments to and from you and other details of products and services you have purchased from us, contact history, purchase history, saved items
From you
Automatically from our information technology systems and our customer relationship management software
From providers of technical payment and delivery services
To enter into/perform our contract with you
Legitimate interest: to keep our records up to date
Legitimate interest: to  monitor how customers use our products and services for the purposes of business management and planning and to identify whether any other products or services may be of interest to you
To enter into/perform our contract with you
To keep our records up to date
For business management and planning
To identify future customer demand
Information involving feedback, questions and complaints received by us from you in relation to our products and services and your responses to surveys, competitions and promotions
From you
To enter into/perform our contract with you
Legitimate interest: to maintain accurate records and to comply with legal, regulatory and corporate governance obligations and good practice
To perform our contract with you
To maintain accurate records and to comply with legal, regulatory and corporate governance obligations and good practice
Technical data, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our app or websites
Automatically as you interact with our app or websites by using cookies, server logs and other similar technologies. We may also receive this data about you if you visit other apps or websites employing our cookies. Please see our Cookie Policies on our app or websites for further details
Legitimate interest: to ensure that our app and websites are user friendly and work for you and other customers
Legitimate interest: to define types of customers for our products and services, to keep our app and website updated and relevant, to develop our business and to inform our marketing strategy
To ensure that our app and websites are user friendly and work for you and other customers
To define types of customers for our products and services, to keep our app and  website updated and relevant, to develop our business and to inform our marketing strategy
We may share this information with selected third parties including our information technology and marketing advisers
Profile data, including your username and password, location, purchases or orders made by you, your interests, preferences, feedback and survey responses, personal or professional interests, information from accounts you link to us e.g. LinkedIn.
From you
Automatically as you interact with our app and websites by using cookies, server logs and other similar technologies. We may also receive this data about you if you visit other apps and websites employing our cookies
Legitimate interest: to define types of customers for our products and services, to keep our app and website updated and relevant, to develop our business and to inform our marketing strategy
To define types of customers for our products and services, to keep our app and website records updated and relevant, to develop our business and to inform our marketing strategy
To study how customers use our products/services
We may share this information with selected third parties, including our information technology and marketing advisers
Usage data, including information about how you use our app, websites, products and services
From you
Automatically as you interact with our app and  websites by using cookies, server logs and other similar technologies. We may also receive this data about you if you visit other apps and websites employing our cookies
Legitimate interest: to ensure that our app and websites are user friendly and work for you and other customers
Legitimate interest: to define types of customers for our products and services, to keep our app and website updated and relevant, to develop our business and to inform our marketing strategy
To ensure that our app and websites are user friendly and work for you and other customers
To define types of customers for our products and services, to keep our app and website/records  updated and relevant, to develop our business and to inform our marketing strategy
We may share this information with selected third parties, including our marketing advisers
Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences
From you
Legitimate interest: to keep our records up to date and to understand how you wish for us to communicate with you
To enter into/perform our contract with you
To keep our records up to date and to understand how you wish for us to communicate with you
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