This privacy policy applies between you, and ihp:ANALYTICS – ihp:ANALYTICS takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected from you in relation to your use of ihp:ANALYTICS services within the context of an ihp:ANALYTICS wellbeing programme.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.ihp-analytics.com/terms-and-conditions.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

2. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includesfirms, companies, government entities, trusts and partnerships;
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of ihp:ANALYTICS Ltd and Users with respect to the use of data collected during an ihp:ANALYTICS wellbeing programme.
4. For purposes of the applicable Data Protection Laws, the “data controller” determines the purposes for which, and the manner in which, your Data are processed:
   • If you are participating in an ihp:ANALYTICS Ltd programme through your employer or organisation, then that employer/organisation will normally remain the “data controller” for your Data (as stipulated in the contract between the employer/organisation and ihp:ANALYTICS Ltd).
   • If you are participating in an ihp:ANALYTICS Ltd programme as an individual, then ihp:ANALYTICS Ltd will be the data controller.

Data collected

5. We may collect the following Data, which includes personal Data, either directly from yourself; via our mobile applications; or via wearable devices:
   1. Contact information (if applicable)
   2. Health and activity information (from wearable devices)
   3. Psychometric (personality, mood) information
   4. Cognitive test data (pattern memory, task switching, etc.)
   5. Context information (hours of work, type and frequency of different kinds of work, etc.)
   6. Lifestyle information (self-reported sleep and activity levels, etc)
   7. Other calculated body metrics (if applicable)
   8. Calculated Health information (derived from the above)

   Please Note: Depending on the wearable device type and set-up, GPS location information may also be sent sometimes from the device. However, GPS location information will not be used by ihp:ANALYTICS Ltd or stored in any ihp:ANALYTICS Ltd systems.

   …in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:
   1. data are given to us by you; and
   2. data collected during assessments on our mobile applications; and
   3. once consent is given, data will be collected automatically when you synchronise your wearable device.

Data that is given to us by you

7. 1. ihp:ANALYTICS Ltd will collect your Data in a number of ways, for example:
   1. when you initially sign-up and register for an ihp:ANALYTICS Ltd programme;
   2. when you use our services;

7. 2. Right to withdraw consent:

   the right to withdraw your consent for processing your data at any time.

    

   …in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you consent to share data from your wearable device, we will collect your Data automatically when you synchronise your device.
9. Cognitive data will be derived and collected automatically when completing cognitive assessments on our mobile applications.

Our use of Data

10. Any or all of the above Data may be required by ihp:ANALYTICS in order to provide you with wellbeing services delivered within an ihp:ANALYTICS Ltd programme. Specifically, Data may be used by us for the following reasons:
11. the calculation and assessment of personalised wellbeing metrics in support of our service to you;
12. assessment of health and wellbeing measures by authorised ihp:ANALYTICS Ltd professional advisors and wellbeing practitioners, for the purposes of providing confidential advice and support to help you improve your health and/or wellbeing;
    1. (where consent has been given) the provision of anonymised and aggregated wellbeing metrics and insights as part of an agreed service to your employer/organisation.
13. When you (or your employer/organisation) register with ihp:ANALYTICS and set-up an account to receive our services, the legal basis for this processing is the performance of a contract between you (or your employer/organisation) and ihp:ANALYTICS and/or taking steps, at your request, to enter into such a contract.

…in each case, in accordance with this privacy policy.

14. When you (or your employer/organisation) register with ihp:ANALYTICS and set-up an account to receive our services, the legal basis for this processing is the performance of a contract between you (or your employer/organisation) and ihp:ANALYTICS and/or taking steps, at your request, to enter into such a contract.

Who we share Data with

15. We may share your Data with the following groups of people for the following reasons:
    1. any of our group companies or affiliates – to ensure the proper administration of the ihp:ANALYTICS Ltd service and business;
    2. our authorised employees, agents and/or professional advisors;

Keeping Data secure

16. We will use technical and organisational measures to safeguard your Data, for example:
    1. access to your account is controlled by a password and a username that is unique to you.
    2. access to systems and data are restricted to authorised ihp:ANALYTICS Ltd personnel who have a legitimate need.
    3. we store your Data on secure servers. All Data are encrypted both in transit and in storage.
17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse, loss or unauthorised access to your Data, then please let us know immediately by contacting us via this e-mail address: info@ihp-analytics.com.
18. If you want detailed information from, “Get Safe Online” on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, then please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

19. Unless a longer retention period is required or permitted by law, ihp:ANALYTICS will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
20. Even if we delete your Data, it may persist on back-up or archival media for a period of time, for legal, tax or regulatory purposes.

Your rights

21. You have the following rights in relation to your Data:
    1. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct– the right to have your Data rectified if they are inaccurate or incomplete.
    3. Right to erase– the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data– the right to “block” us from using your Data or limit the way in which we can use it.
    5. Right to data portability – the right to request that we move, copy or transfer your Data.
    6. Right to object– the right to object to our use of your Data including where we use it for our legitimate interests.

22. To make enquiries, exercise any of your rights as set-out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), then please contact us via this E-mail address: info@ihp-analytics.com.
23. If you are not satisfied with the way that a complaint you make in relation to your Data is handled by us, then you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
24. It is important that the Data we hold about you are accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Changes of business ownership and control

25. ihp:ANALYTICS Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or transfer of control of all or part of ihp:ANALYTICS Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to (only) use the Data for the purposes for which it was originally supplied to us and to ensure services are maintained.
26. In the above instances, we will take all necessary/appropriate steps with the aim of ensuring your privacy is protected.

General

27. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
28. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
29. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
30. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

31. ihp:ANALYTICS Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted immediately on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.   You may contact ihp:ANALYTICS Ltd by e-mail at info@ihp-analytics.com.  

iHP Analytics Ltd Registered office: Goodwood House, Mary Street, Taunton, Somerset, TA1 2PX. Company Registration number 12561270 

This privacy policy applies between you, and ihp:ANALYTICS – ihp:ANALYTICS takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected from you in relation to your use of ihp:ANALYTICS services within the context of an ihp:ANALYTICS wellbeing programme.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.ihp-analytics.com/terms-and-conditions.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

2. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includesfirms, companies, government entities, trusts and partnerships;
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of ihp:ANALYTICS Ltd and Users with respect to the use of data collected during an ihp:ANALYTICS wellbeing programme.
4. For purposes of the applicable Data Protection Laws, the “data controller” determines the purposes for which, and the manner in which, your Data are processed:
   • If you are participating in an ihp:ANALYTICS Ltd programme through your employer or organisation, then that employer/organisation will normally remain the “data controller” for your Data (as stipulated in the contract between the employer/organisation and ihp:ANALYTICS Ltd).
   • If you are participating in an ihp:ANALYTICS Ltd programme as an individual, then ihp:ANALYTICS Ltd will be the data controller.

Data collected

5. We may collect the following Data, which includes personal Data, either directly from yourself; via our mobile applications; or via wearable devices:
   1. Contact information (if applicable)
   2. Health and activity information (from wearable devices)
   3. Psychometric (personality, mood) information
   4. Cognitive test data (pattern memory, task switching, etc.)
   5. Context information (hours of work, type and frequency of different kinds of work, etc.)
   6. Lifestyle information (self-reported sleep and activity levels, etc)
   7. Other calculated body metrics (if applicable)
   8. Calculated Health information (derived from the above)

   Please Note: Depending on the wearable device type and set-up, GPS location information may also be sent sometimes from the device. However, GPS location information will not be used by ihp:ANALYTICS Ltd or stored in any ihp:ANALYTICS Ltd systems.

   …in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:
   1. data are given to us by you; and
   2. data collected during assessments on our mobile applications; and
   3. once consent is given, data will be collected automatically when you synchronise your wearable device.

Data that is given to us by you

7. 1. ihp:ANALYTICS Ltd will collect your Data in a number of ways, for example:
   1. when you initially sign-up and register for an ihp:ANALYTICS Ltd programme;
   2. when you use our services;

7. 2. Right to withdraw consent:

   the right to withdraw your consent for processing your data at any time.

    

   …in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you consent to share data from your wearable device, we will collect your Data automatically when you synchronise your device.
9. Cognitive data will be derived and collected automatically when completing cognitive assessments on our mobile applications.

Our use of Data

10. Any or all of the above Data may be required by ihp:ANALYTICS in order to provide you with wellbeing services delivered within an ihp:ANALYTICS Ltd programme. Specifically, Data may be used by us for the following reasons:
11. the calculation and assessment of personalised wellbeing metrics in support of our service to you;
12. assessment of health and wellbeing measures by authorised ihp:ANALYTICS Ltd professional advisors and wellbeing practitioners, for the purposes of providing confidential advice and support to help you improve your health and/or wellbeing;
    1. (where consent has been given) the provision of anonymised and aggregated wellbeing metrics and insights as part of an agreed service to your employer/organisation.
13. When you (or your employer/organisation) register with ihp:ANALYTICS and set-up an account to receive our services, the legal basis for this processing is the performance of a contract between you (or your employer/organisation) and ihp:ANALYTICS and/or taking steps, at your request, to enter into such a contract.

…in each case, in accordance with this privacy policy.

14. When you (or your employer/organisation) register with ihp:ANALYTICS and set-up an account to receive our services, the legal basis for this processing is the performance of a contract between you (or your employer/organisation) and ihp:ANALYTICS and/or taking steps, at your request, to enter into such a contract.

Who we share Data with

15. We may share your Data with the following groups of people for the following reasons:
    1. any of our group companies or affiliates – to ensure the proper administration of the ihp:ANALYTICS Ltd service and business;
    2. our authorised employees, agents and/or professional advisors;

Keeping Data secure

16. We will use technical and organisational measures to safeguard your Data, for example:
    1. access to your account is controlled by a password and a username that is unique to you.
    2. access to systems and data are restricted to authorised ihp:ANALYTICS Ltd personnel who have a legitimate need.
    3. we store your Data on secure servers. All Data are encrypted both in transit and in storage.
17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse, loss or unauthorised access to your Data, then please let us know immediately by contacting us via this e-mail address: info@ihp-analytics.com.
18. If you want detailed information from, “Get Safe Online” on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, then please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

19. Unless a longer retention period is required or permitted by law, ihp:ANALYTICS will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
20. Even if we delete your Data, it may persist on back-up or archival media for a period of time, for legal, tax or regulatory purposes.

Your rights

21. You have the following rights in relation to your Data:
    1. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct– the right to have your Data rectified if they are inaccurate or incomplete.
    3. Right to erase– the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data– the right to “block” us from using your Data or limit the way in which we can use it.
    5. Right to data portability – the right to request that we move, copy or transfer your Data.
    6. Right to object– the right to object to our use of your Data including where we use it for our legitimate interests.

22. To make enquiries, exercise any of your rights as set-out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), then please contact us via this E-mail address: info@ihp-analytics.com.
23. If you are not satisfied with the way that a complaint you make in relation to your Data is handled by us, then you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
24. It is important that the Data we hold about you are accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Changes of business ownership and control

25. ihp:ANALYTICS Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or transfer of control of all or part of ihp:ANALYTICS Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to (only) use the Data for the purposes for which it was originally supplied to us and to ensure services are maintained.
26. In the above instances, we will take all necessary/appropriate steps with the aim of ensuring your privacy is protected.

General

27. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
28. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
29. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
30. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

31. ihp:ANALYTICS Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted immediately on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.   You may contact ihp:ANALYTICS Ltd by e-mail at info@ihp-analytics.com.  

iHP Analytics Ltd Registered office: Goodwood House, Mary Street, Taunton, Somerset, TA1 2PX. Company Registration number 12561270