Privacy Policy

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, Bastion House, 6th Floor, 140 London Wall, London EC2Y 5DN, 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.se 

• Postal address: Champion Health Ltd, Bastion House, 6th Floor, 140 London Wall, London EC2Y 5DN, United Kingdom 

CONSENT 

Before installation or access to the Platform, you will be asked to indicate your consent to our processing of 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 process your personal data for specified processing activities (see online registration form) you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any 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. 

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 

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 

DISCLOSURES OF YOUR PERSONAL DATA 

When you provide us with your personal data, we may share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data: 

1. External Third Parties as set out in the Glossary. 

1. Specific third parties such as Stripe, Inc, GoCardless and Xero. 

1. 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. 
• 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. 

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 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.se 

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. 

3. 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. 

Privacy Policy – User

Champion Health User Privacy Policy

(Updated April 2022)

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 or as presented to you when you first use or install any of our Platform (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 or online through our website “web platform” (Platform Site) or the relevant application market on your device, 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);
• Any of the services accessible through the Platform or the Platform Site via any Device (Services) that are available on the Platform Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us as part of our Services provided via the Platform; and
• No matter how you interact with us, by phone or computer, this policy will govern the processing of your personal data that we carry out and where we do something specific to either mobile or web (depending on what versions of our Platform you use) then we will make it clear where that kind of processing only applies to either our mobile application, or our web application versions of the Platform.

The Platform are 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. Authorized 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, Bastion House, 6th Floor, 140 London Wall, London EC2Y 5DN, United Kingdom. We are the controller who is responsible for your personal data (collectively referred to as, “we“, “us” or “our” in this policy).

Our contact details

• Email address: support@championhealth.se

• Postal address: Champion Health Ltd, Bastion House, 6th Floor, 140 London Wall, London EC2Y 5DN, United Kingdom

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.

DPO contact details

Our DPO’s contact details are:

• Name or title of DPO: Rosalind Watchorn

• Email address: ros.watchorn@championhealth.se
• Postal address: 23, Kenwood Park Road, Sheffield, S7 1NF

CONSENT

Before installation or access to the Platform, you will be asked to indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.

How you can withdraw consent

Once you provide consent by acknowledging your agreement to our terms of service and data processing (see online registration form) you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information only where this strictly required for insurance purposes or other legal compliance, but we will delete anything we don’t strictly need to comply with our own legal obligations as we are required to by the GDPR. We won’t be able to remove any data you provided that we have fully anonymized 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)
• Financial Data.
• Transaction Data.
• Device Data.

• Content Data.
• Profile Data.
• Usage Data.
• App Data.
• Marketing and Communications Data.

We will be collecting Special Categories of Personal Data about you (the definition of Special Categories 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).

If you use our Services then you will be providing us with Special Category of personal data, and because this may be provided via a free-text response by email, online contact form or over the phone, then by providing this information you are deemed to consent to our processing of that data in accordance with this policy. We do not collect any information about criminal convictions and offences. We will ask for your consent when you first use or install the Platform and thereafter we will only ask for your consent again if the purpose of our processing changes.

We only collect financial and transaction data if you pay us directly for our Services. We do not collect financial or transaction data where your employer or a family member or friend provides you with access to our Services.

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.

Contact Data: billing address, delivery address, email address and telephone numbers.

Financial Data: bank account and payment card details.

Transaction Data: includes details about payments to and from you and details of in-Platform purchases.

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 information stored on your Device, including login information, photos, videos or other digital content.

Profile Data: includes your username and password, in-Platform purchase history, 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, whether this is required for our own billing purposes or otherwise 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 also create, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data as described above, which includes your Health Data (Special Category), but is not considered personal data in law as this data will not directly or indirectly reveal your identity. This data falls outside of the scope of the GDPR and the UK Data Protection laws because it can’t be linked back to you. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific 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.

This policy doesn’t necessarily need to describe what we do with aggregated data, the GDPR says this kind of data falls outside its scope because you can no longer be identified from it, but we still want to tell you about what we plan to do with this data anyway.

We will use aggregated or anonymized data for research and scientific purposes in order to either try and improve the way we deliver our own services, or for other bodies and organizations to improve the ways in which they deal with and manage the health of their employees in the workplace. We also want to work with research groups and universities and use this data, in combination with other data sets, to help us and those third-party researchers understand health and wellbeing so that together we can try to understand the root cause and impact it has on people’s health. We might work with other people or companies for the same purposes from time to time, and we will do our best to tell you all about it on our website, or as part of our newsletter.

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, then please contact us to let us know before you use our Platform or any of our Services. Because of the way in which we anonymize and aggregate data, we won’t be able to tell which data is yours if you decide you want to try to “opt-out” of this in the future, and if you do decline this processing of non-personal data then we might not be able to provide parts of our Services to you at all.

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 the Platform Site, download, register or use an Platform for the first time, subscribe to any of our Services, search for an 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. Please see our cookie policy below for further details.

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.

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

COOKIES

We use cookies and other tracking technologies such as pixels to distinguish you from other users of our Platform, the Platform Site, the distribution platform (relevant appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the Platform or browse any of Our Sites and also allows us to improve the Platform and Our Sites. 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.

DISCLOSURES OF YOUR PERSONAL DATA

When you provide us with your personal data, we may share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

1. External Third Parties as set out in the Glossary.
2. Specific third parties such as Stripe, Inc, GoCardless and Xero.
3. 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
• 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

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

MARKETING

We will only send you direct marketing communications by email and only then if we have your approval at the point of registration for access to our digital platforms or when requesting information through our website. We will ask you to opt-in to receiving such marketing communications before we send anything to you. You have the right to opt-out of receiving marketing from us at any time using the unsubscribe link in our emails.

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

We never send you marketing based on your Health Data, and we will never share your Health Data with third parties unless you can’t be linked to that information (so that it is no longer personal data).

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 by the European Commission which give personal data the same protection it has in Europe. 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.

DATA SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone else.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. Data is secured using a Next Generation firewall and hosted on a secure web hosting platform. Systems are penetration tested annually (scheduled) and Cyber Essentials certified. Systems are monitored and patched regularly ensuring security risks are mitigated.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

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

DATA RETENTION

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymize 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.

In the event that you do not use the Platform for a period of twenty years then we will treat the account as expired and your personal data may be deleted.

YOUR LEGAL RIGHTS

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

• Your rights allow you to request; 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.

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.se

How you can withdraw consent

Once you provide consent by acknowledging your agreement to our terms of service and data processing (see online registration form) you may change your mind and withdraw consent at any time by contacting us (support@championhealth.se) but that will not affect the lawfulness of any processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information only where this strictly required for insurance purposes or other legal compliance, but we will delete anything we don’t strictly need to comply with our own legal obligations as we are required to by the GDPR. We won’t be able to remove any data you provided that we have fully anonymized as part of an Aggregated data set (which we describe below) that doesn’t reveal any individual’s identity.

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 05/04/2022 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.

Delivery services who we instruct in order to deliver our products and services to you who will be based in the United Kingdom where this is required in order to actually carry out and deliver your order.

3. 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.