Privacy Policy

SUMMARY

● UNIHEADS is a licenced product of Champion Health Ltd.

● UNIHEADS is a digital online mental health training platform. Services include online mental health training for students, university staff and accommodation provider staff.

● UNIHEADS does not sell on any data to third parties.

● UNIHEADS does not share user data with any third parties other than those who provide IT and system administration to enable the fulfilment of our services.

● UNIHEADS does not collect any special category data (health data). This training platform does not ask questions about the state of the user’s mental health, it provides educational content only.

● UNIHEADS’ systems are annually penetration tested. Data is secured using a next-generation firewall and hosted on a secure web hosting platform (Microsoft Azure, London, UK). UNIHEADS is Cyber essentials certified. Systems are monitored and patched regularly ensuring security risks are mitigated.

The only data UNIHEADS collects from student users is:

Identity, Contact, Marketing & Communications Data*

Name & Email address

● User details are collected in order to create an account so that student progress within the training is stored and users can return back to at any time.

● User progression, completion and feedback data is anonymised and aggregated. The summary of this data is only shared with the a student provider (eg your university or your accommodation provider) IF your provider has purchased the UNIHEADS PROVIDER+ package and this sharing is solely for monitoring the scale of impact of the training upon students. Your identify cannot be identified.

University & Accommodation Provider Details (eg Course of study , Year of study, University attended, Accommodation provider, Accommodation Residence)

● This enables student users to access content bespoke to their university provider (only when a University has purchased the UNIHEADS PROVIDER+ package ) and to assign anonymised data sharing as described above.

● This enables student users to access content bespoke to their accommodation provider (only when a University has purchased the UNIHEADS PROVIDER+ package) and to assign anonymised data sharing as described above.

Device, Content, Profile & Usage Data

User Feedback

● This data is used solely to improve our services and to gauge the impact that training is having. and to assign anonymised data sharing as described above (only when a University or Provider has purchased the UNIHEADS PROVIDER+ package).

● This data is anonymised and may be used within future UNIHEADS marketing campaigns.

*Further details can be found within ‘The Data We Collect About You’ section.

CONSENT TO INSTALLATION OF/ ACCESS TO THE APPS

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.

Before installation or access to the Apps, please indicate your consent to our processing of your personal data (including your name, contact details and device information) as described in this policy.

How you can withdraw consent

Once you provide consent by selecting “YES” (or via tick box functions) you may change your mind and withdraw consent at any time by contacting UNIHEADS (support@uniheads.co.uk) 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, only where this is 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 anonymised as part of an Aggregated data set (which we describe below) that doesn’t reveal any individual’s identity.

UNIHEADS (the trading name for Champion Health Ltd (we, us, our) are committed to protecting your personal data and respecting your privacy.

INTRODUCTION

The Apps 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. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

· IMPORTANT INFORMATION AND WHO WE ARE

· THE DATA WE COLLECT ABOUT YOU

· HOW IS YOUR PERSONAL DATA COLLECTED?

· HOW WE USE YOUR PERSONAL DATA

· DISCLOSURES OF YOUR PERSONAL DATA

· INTERNATIONAL TRANSFERS

· DATA SECURITY

· DATA RETENTION

· YOUR LEGAL RIGHTS

· GLOSSARY

· DESCRIPTION OF CATEGORIES OF PERSONAL DATA

· IMPORTANT INFORMATION AND WHO WE ARE

Champion Health Ltd a company registered in England and Wales with company registration number 11456257 of with registered address at 10 Kenwood Park Road, Sheffield, United Kingdom, S7 1NF. We are the controller who is responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this policy).

UNIHEADS is a product developed and licenced by Champion Health Ltd.

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 full contact details are:

· Full name of legal entity: Champion Health Ltd

· Name or title of DPO: Rosalind Watchorn

· Email address: ros.watchorn@championhealth.co.uk

· Postal address: 23, Kenwood Park Road, Sheffield, S71NE

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 App 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 on 08/10/2020. It may change and if it does, these changes will be posted and, where appropriate, notified to you by email when you next start the Apps or log onto one of the App 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 Apps 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.

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.

· Device Data.

· Content Data.

· Profile Data.

· Usage Data.

· Marketing and Communications Data.

We won’t be collecting any 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).

We do not collect any information about criminal convictions and offences. We will ask for your consent when you first use or install the App and thereafter we will only ask for your consent again if the purpose of our processing changes.

AGGREGATED DATA & ANONYMISATION

We also create, use Aggregated Data relating specifically to the use of the App and share this data with the University and/or accommodation provider for the purpose of monitoring the impact of UNIHEADS services.

Aggregated Data could be derived from your personal data as described above, 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 App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 anonymised 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 organisations to improve student mental health outcomes. 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 App or any of our Services. Because of the way in which we anonymise 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 and Marketing and Communications Data) you consent to give us information about you by filling in forms whilst using our App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download, register or use an App for the first time, subscribe to any of our Services, search for an App 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 Apps, 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 Apps 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;

· Identity Data, Contact Data, Device Data, Content Data, Profile Data, Usage Data, Marketing and Communications Data from our third-party IT services providers who manage and run our App 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.

COOKIES

We use cookies and other tracking technologies such as pixels to distinguish you from other users of our Apps, the App 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 App or browse any of Our Sites and also allows us to improve the App 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.

Cookie Name Purpose

__utma This cookie is used to monitor the number of times a visitor has been to the site related to the cookie, when they first visited the site, and when they were last on the site. Google Analytics uses the information from this cookie to calculate things like Days and Visits to purchase. More information

__utmb

__utmc These two cookies work together to establish how long a visit has taken. b signals when a user enters the site and c signals when a user leaves. More information

__utmt A cookie used to throttle the request rate for the service, limiting the collection of data on high traffic sites. More information

__utmz This cookie captures how a visitor accessed the site including: which search engine was used, what link was clicked on, what keywords were used and geographical location. More information

Facebook Pixel A cookie issued to monitor traffic directed to our website from Facebook. This is used to provide relevant feedback to the user based on the content in which they have shown interest in. It is also used to gauge the effectiveness of our digital marketing campaigns. A user can opt out on the Facebook site. More Information

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.

· To protect your vital interests where you are unable to give consent.

We will only send you and platform users direct marketing communications by email and only then if we have your approval. 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 by contacting us or changing your marketing preferences.

We will get yours and (other user’s) explicit opt-in consent before we use and share data personal data between the university and UNIHEADS. We do not share data with any third party for marketing purposes.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/activity Type of data Lawful basis for processing

To install the App and

register you as a new App

user Identity Contact Device Performance of a contract with you.

To deliver our Services Identity Contact Device Marketing and Communications Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) Where necessary to protect your vital interests where you cannot give consent.

To manage our relationship with you including notifying you of changes to the App or any Services Identity Contact Profile Marketing and Communications Performance of a contract with you. Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)