Mind over Tech respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our platform, app and website (“Site”) and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us
- Your rights relating to your Personal Data
- Marketing communications preferences
- What Personal Data we collect
- How we use your Personal Data and why
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources
- Who we share your Personal Data with
- How we keep your Personal Data secure
- How long we store your Personal Data
- Our policy on children
- Third party links
Who we are and how to contact us
Who we are
How to contact us
You can contact us by emailing: firstname.lastname@example.org.
Our Data Protection Officer
Your rights relating to your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us at email@example.com.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences
If you sign up to receive email newsletters or promotional materials from us we will use the information you give us to provide the communications you have requested. You can ask us to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. If you no longer wish to receive push notifications, 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 which help you administer your account and allows us to update you when our Site changes or you receive notifications on your account.
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of the individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of personal data collected|
|Contact Data||Email address|
|Marketing and Communications Data||Your preferences in receiving marketing from us and your communication preferences.|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this website or use our services.|
|User-Generated Data||Information in the Site which you have chosen to bookmark for ease of access at a later date.|
How we use your Personal Data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Categories of personal data involved||Why do we do this||Our legal basis for this use of data.|
|Account Creation||• Contact Data||To register you as a new user.||Contractual Necessity.|
|Site Operation||• Contact Data• User-Generated Data||To provide you with the services offered on our Site (including technical support services), such as for example, “Pinned Lessons” (helping you find content you liked more easily).||Contractual Necessity|
|Aggregation for affiliated or associated organisations (e.g. employers, academic institutions, governing bodies)||• Identity Data• Contact Data• User-Generated Data||In an anonymised, aggregated format to demonstrate the average wellbeing of different populations, to identify usage patterns across and between sub-groups locations, to extrapolate whether use of the Site is more beneficial for some audiences compared to others. These aggregated reports do not contain Personal Data related to your Mind over Tech account or any personally identifiable User Generated Data.||Legitimate Interests.We have a legitimate interest in understanding our end-users to develop the Mind over Tech offering, to publish white papers and to share this anonymous data with health professionals and researchers. To the extent your User Generated Data contains Special Categories of Personal Data, we rely on the Research Ground.|
|Fraud Prevention||• Technical Data• Contact Data||To keep our website, our services and associated systems operational and secure.||Legitimate Interests.We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.|
|Troubleshooting||• Technical Data||To track issues that might be occurring on our systems.||Legitimate Interests.It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.|
|Marketing||• Contact Data• Marketing and Communications 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 services and offers may be relevant for you.||Consent|
What happens when you do not provide necessary Personal Data?
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, 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 the functionalities of the Site).
In this case, we may have to stop you from using our Site or revoke your Mind over Tech account but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Categories or other types of personal data received|
|Your Employer(s), academic institution(s), governing bodies||No||• Contact Data|
|Analytics Providers||No||• Technical Data|
What are 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.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Your Employer(s) academic institutions, governing bodies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
As true of most websites, we gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our emails, your opening of the email is notified to us and saved. Your clicks on links in the emails are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
Who we share your Personal Data with
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share||Why we share it|
|Service Providers||• Contact Data• Technical Data• User Generated Data• Marketing and Communications Data||Our service providers provide us with IT and system administration services.|
|Professional advisers||• Identity Data• Contact Data||Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.|
|HM Revenue & Customs, regulators and other authorities||• Identity Data• Contact Data||Authorities may require reporting of processing activities in certain circumstances|
Some of the third parties with whom we may share your Personal Data are based outside the UK and European Economic Area (“Europe”) so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
• Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
• Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Europe.
How we keep your Personal Data secure
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.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out in this policy, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|• Marketing and Communications Data• Technical Data||For so long as you have anAccount with Mind over Tech or our Site(s).|
|• Contact Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used.|
|• User-Generated Data||For so long as you have an Account with Mind over Tech or our Site(s).|
Our policy on children
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children. You should not use the Site if you are below 16.
Third party links