MindOO Privacy Policy

Introductory Text

This Privacy Policy describes how MindOO collects, uses, and shares your personal information. We know that these aren’t always the easiest documents to read, so we have tried to make this Policy as short and easy to understand as possible.

We make updates to this Policy and will let you know by email when we do, so we encourage you to come back and have another look when you receive an update notification from us.

If you are one of our users or clients who access our platform from outside the United Kingdom (UK), you may have certain additional privacy rights so make sure you check the side menu to see if there is another privacy page for the country you are living in.

If there’s something that doesn’t make sense, or you would like to know more about, please send an email to privacy@mindoo.org and we’ll get back to you as soon as we can.

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Who are we?

We are Mental Health support Ltd., an organisation that empowers employees with evidence-based digital tools to proactively manage and improve their mental wellbeing.

Category of Personal Data - What it means?

Identity Data

First and last name, email address, date of birth*, location, department/team, employee number (or similar identifier provided by an employer if required). *Users who sign up to MindOO via one of our 3rd Party Health & Wellbeing partners may be required to provide us with their date of birth on sign up. This will be deleted as soon as registration eligibility is confirmed.

Marketing and Communications Data

Your preferences in receiving marketing and other communications from us.

Behavioural Data

This is inferred or assumed information relating to your behaviour and interests, based on your online activity. This information helps us understand the popularity of our features and to tailor your experience.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, device ID, usage data, operating system and platform and other technology on the devices you use to access this website or use our services. You can contact us via the contact details at the end of this policy if you would like the full list of technical data collected. Technical data also includes intelligence experience information such as recording what links you click on and how often you visit certain pages.

User-Generated Data

Information and content that you submit to our platform such as when you fill in free text fields.

Aggregated Data

Aggregated data is information that we collect from multiple sources and individuals in an anonymous format which allows us to prepare data summaries or summary reports for our clients (your employer). Aggregated Data does not constitute Personal Data as it does not directly or indirectly reveal your identity.We have an anonymity threshold of six people or more. This means that we will endeavour to ensure that we do not anonymise or aggregate any personal data where there are less than six people within the dataset to prevent the risk of it becoming identifiable again.

Special Category Data

Special Categories of Personal Data are data that include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetics, and biometric data. Since you are able to upload details of your mood or mental state on our platform, the data you provide us may contain data relating to your health or other Special Categories of Personal Data. Using this feature is optional; MindOO will never require you to provide us with special category data in order to use our service.

How we collect your information

When you sign up

When you sign up use our platform, we will collect your identity and contact information so that we can send you a registration email and so that we can validate your eligibility and create an account for you.

When you use MindOO

We will continue to collect information such as your activity on our platform, your communication preferences, and any support requests you may have whenever you interact with the MindOO platform.

We also collect information through a variety of technologies, such as cookies (you can read more about this in our Cookies Policy) and via analytics tools such as third-party experience intelligence providers. This enables us to better understand your experience by recording details such as how much time you spend on certain pages and tools, and which links you choose to click. These details assist us in understanding what content you and other users do and don’t like and hence, allows us to constantly improve our offering to you.

We always have appropriate data processing agreements in place with any experience intelligence providers to ensure that your data is protected in line with this Privacy Policy.

Information from Third-Party Sources

In addition to the Personal Data that we collect directly from you, we may also collect information from third parties. These might include your employer, our 3rd Party Health & Wellbeing Partners, the provisioner of your “guest” account (where your MindOO access has been granted by a friend, family member, or peer) or analytics providers

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How we use your information?

We collect, use, and share the data on the following legal grounds:

With your consent. We may ask for you to consent to certain activities when you sign up with us; we will only use your information for the explicit purposes for which you have consented to. You can withdraw your consent at any time
As necessary to fulfil our Terms and Conditions contract with you
As necessary to comply with our legal obligations
As necessary for our (or others') legitimate interests, including our interests in providing a helpful, personalised and safe service to you.

Our purposes for using your information are primarily to:

Registration: Send you a registration email and register you as a new user.
Service and Support: Provide you with the services offered on our Site (including technical support services), such as for example, “Insights” (helping you to track your wellbeing).
Surveys: Complete surveys and obtain data for research purposes and in an anonymised format (although you do not have to respond to such surveys).
Praise: Send you your colleagues’ praises.
Research and Development: In an anonymised format, to develop the MindOO offering, to create and distribute white papers, to conduct and publish research, and to share the data with health professionals and academics to improve MindOO and other services relating to mental wellbeing.
Fraud Prevention: To keep our website, our services, your Personal Data and associated systems operational and secure.
Communication and Marketing: When you sign up to using our platform, we will email you newsletters, course reminders and some promotional materials.
When you download our app, you will be asked if you would like to receive push notifications. If you consent to this, but change your mind later, you may turn them off at the device level. Where you opt out of receiving these marketing messages, this will not apply to service correspondence that allows us to help you administer your account, notifications about your account or any updates we might send you about our Site changes.

What happens if you don’t provide us with the right information?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, you may not be able to use our platform.

In this case, we may have to stop you from using our Site or revoke your MindOO account, but we will notify you if this is the case at the time.

3rd Party Health & Wellbeing Partners

Members creating an MindOO account through one of our 3rd Party Health and Wellbeing Partners may be required to provide us with their date of birth alongside their full name and email address. We will use this information to validate it against our partners’ data in order to confirm your eligibility for an account. We may not be able to confirm your eligibility without this information.

We will not retain your date of birth details after eligibility has been confirmed, but your name and email will be retained in order to complete the account creation (see How do we use your personal data and why?).

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Who do we share your information with?

We may need to share your personal information with third-party data processors so that we can use their technology to improve the MindOO experience for you. But you don’t need to worry because we have a detailed screening process in place to ensure that we only work with companies we trust.

Below is a non-exhaustive list of when we may share your personal information with a third-party

With companies who provide us with IT and system administration services so that we can offer a smooth, uninterrupted and safe experience for you;
With trusted technical and professional consultants, external auditors and our legal advisors who may require access to personal data on an ad hoc basis and only with a relevant purpose; such as maintaining the security of our service or within the provision of professional services.
With authorities who may require reporting of processing activities in specific circumstances such as complying with applicable law or responding to a valid legal process from law enforcement or other government agencies.
With the provisioner of your “guest” account (where your MindOO access has been granted by a friend, family member, or peer) so that we can maintain and validate your “guest” account.
With our 3rd Party Health & Wellbeing Partners to ensure that users who sign up via this method receive points towards their Rewards system when they complete relevant activities.

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What are your rights?

By law, you have ten important rights when it comes to your personal information.

The right to object to processing: You have the right to object to certain types of processing, including processing for direct communications (for instance, if you don’t want us to send you any more emails).
The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights (this is why we ask you to read this page).
The right of access: You have the right to access your information (if we’re processing it) so that you can check we are processing it in alignment with data protection law.
The right to rectification: You can correct your personal details from your account settings, but if you’re having trouble, you can contact us and request that we fix any information we hold about you that is incorrect.
The right to erasure: You can ask us to delete any information we hold about you. Be careful, this isn’t a general right to erasure; there are exceptions. But we strive to meet your requests where we can.
The right to restrict processing: You have rights to ask us to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but we won’t be able to use it anymore.
The right to data portability: You have rights to obtain and reuse your personal information for your own purposes across different services. If you ask us for your information in a portable format, then that means we will give it to you in an accessible and machine-readable, for example as a csv file. You can also ask us to safely transfer it to another system for you.
The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal information. Please let us know at privacy@mindoo.org if you have an issue. If we can’t fix it for you, you are within your rights to raise it with your national data protection regulator.
The right to withdraw consent: At MindOO, we don’t generally rely on consent as our legal basis for processing your information (unless we need to according to your local data protection law; make sure you read the section How we use your information and check to see if there is different information in your country’s addendum to this page). But, if you have given your consent, for example, for us to email you, then you can change your mind at any time. All you have to do is let us know (e.g., by clicking the unsubscribe button at the bottom of an email, or by emailing us at privacy@mindoo.org.
You have the right to not be subject to a decision based solely on automated processing. But don’t worry, we don’t do that here at MindOO anyway!

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Data security, integrity, and retention of your information

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your information from being misused or accessed by the wrong people.

We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. If you ask us to delete your account, we will delete your contact and ID information within 60 days of your request. Records of your interactions with our platform will be permanently and irrevocably anonymised so that it can never be reconstructed to identify you as an individual. The reason we do this is so that we can create and distribute white papers, conduct, and publish research, and share the data with health professionals and academics to improve MindOO and other services relating to mental wellbeing.

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Data transfers, storage and processing

MindOO are growing quickly and are proud that we can improve the wellbeing of individuals all around the world. This does mean that sometimes, we will need to share, store and process your Personal Data with third-party processors who are located outside of your country.

Our platform is hosted in the European Union (EU) within the United Kingdom(UK), so your information will be processed in the UK. No internal data is transferred outside UK.‍

Our policy on children

We believe that mental health is for everyone, but our platform has been designed for individuals over the age of 16. So, if you are under the age of 16, we encourage you to reach out to an adult or someone you trust but ask that you don’t use our platform.

Cookies and tracking technologies

Cookies

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

You can view our Cookies Policy here.

Third Party Links

This Site 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 your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

Get in touch with us

We understand that this Privacy Policy is a lot to read through, and that there may be concepts or terms that seem strange or unfamiliar to you. Or maybe you you would like to exercise some of the rights you read about in the What are your rights section. If that’s the case, please do reach out to us by emailing our Data Protection Officer at privacy@mindoo.org, we are always happy to have a chat!

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