Consent to installation of the App and processing of your Personal Data
How you can withdraw consent to the use of health data
If you provide consent to the use of health data by selecting “YES” when signing up for the App, you may change your mind and withdraw consent at any time by contacting us at firstname.lastname@example.org, but that will not affect the lawfulness of any processing carried out before you withdraw your consent. It may remove the ability to receive benefits from the App. We will only collect health data when you provide it to us and you agree to provide consent by submitting the data.
- The GoVida mobile application software (App) available on our website and through the relevant App Store or Marketplace, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Important information and who we are
Propel Wellbeing Limited is the Data Controller for the purposes of Data Protection Law, and is responsible for the collection and processing of your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).
Our full details are:
- Full name of legal entity: Propel Wellbeing Limited
- Email address: email@example.com
- Postal address: Copyrite House, 1 Levens Road, Hazel Grove, Stockport, SK7 5DL, United Kingdom
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. We would, however, welcome the opportunity to address any complaint with you directly in the first instance.
This version was last updated on 26th November 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you either by email or when you next start the App. 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 App 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 website and the App 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 and Location 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.
- Location Data
- Health Data (Special Category Data)
We explain these categories of data below.
We collect limited amounts of Special Categories of Personal Data about you. This is the health data you provide to us about your mood and energy. We consider this to be health data as it may show your current mental health. We do also collect activity data through the App’s integration with Apple Health and Google Fit and Fitbit and Strava and Garmin, which is not health data. This data will not be shared with any third party other than your Employer or our technical and user support provider e-Zest Solutions Limited, and will not be transferred outside the EEA save in relation to technical support purposes to e-Zest Solutions Limited, our Technical Support Provider based in India.
It will be deleted irretrievably (subject to our data retention policy below) if and when you delete the App from your device and either:
- You specifically request we delete your account; or
- Your employer does not renew their contract with us; or
- You leave your employment and your employer deletes your account; or
- Your employer requests we delete your account.
We will only collect and use the health data where you have consented to us doing so. Please note that we do not collect health data that you do not provide to us directly. If you have chosen not to consent to our use of the health data you must not provide mood data to us. If you do you will be providing consent for it to be provided to us.
You can withdraw your consent for our processing of your Special Category Data at any time and for any reason, but note you should not then provide this data to us.
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 giving us about you by filling in forms on the when you register to use the App, download or register the App, subscribe to any of our Services, search for an App or Service, share data via the App’s social media functions, enter a challenge or competition, promotion or survey, or redeem an offer or benefit and when you report a problem with an App, our Services, or Our website. If you contact us, we will keep a record of that correspondence.
- Information we collect from other apps. This is information about your activities and may include data about your health or location. We can only capture this data where you allow it by permitting the other app to share data with us.
- Location Data. We also use user-initiated GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- 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:
- Contact and Device Data from providers of technical and delivery services such as e-Zest Solutions Limited, our technical support providers based outside the UK and the EU;
- Identity and Contact Data from the Employer of any user of the App, based inside the UK or EU;
- Identity and Contact Data from publicly available sources such as the electoral register based inside the UK; and
- 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 (which includes the agreement to use the App).
- 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.
Please see the sections below to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
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
Performance of a contract with you
|To process and deliver our Services||Identity
Health (Special Category)
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests
|To manage our relationship with you including notifying you of changes to the App or any Services||Identity
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)
|To enable you to participate in a prize draw, competition, complete a survey or validate your attendance at a location or venue submitted through the GoVida app enable you to earn points, appear on leaderboards with other users take part in challenges and receive rewards and benefits||Identity
Marketing and Communications
Special Category Data
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||Identity
|Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)|
|To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Marketing and Communications
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosures of your Personal Data
Your data will be shared with your employer where you use the App and in some instances may be viewed by other employees of your employer.
We provide Employers with the following information through access to an online portal which provides information on all of their employees making use of the App so that they can provide benefits and rewards:
- a daily, weekly, monthly and annual individual steps leaderboard;
- average daily steps and Average daily distance data for all their employees (combined, not individual)
- total accumulated steps and distance data for all their employees (combined, not individual)
- average weekly check-ins for all their employees (not individual)
- total accumulated “Check-In” data for all their employees (combined and not individual, not which locations and not when)
- weekly average GoVida points earned by their staff (on a combined, not individual basis)
- Total GoVida points earned by their staff (on a combined, not individual basis)
- Total number of rewards redeemed by their staff (on a combined, not individual basis)
- which employee has redeemed any particular employer reward; other users taking part in any Challenge, as part of the Leaderboard.
Service providers acting as processors based outside the UK or EU, including e-Zest Solutions Limited, who provide IT and system administration services.
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 UK who require reporting of processing activities in certain circumstances.
Your employer will be able to view the following data:
- Mind Section data
- Team Challenges
- Charity Earnings
- Reward tracking
Other employees (except where acting for your employer) will be able to view your data shared on leaderboards for Team Challenges.
When you provide us with your consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
- Third Parties as set out in the Glossary below, including your Employer so that they can provide rewards and benefits to you based upon your use of the App and anyone taking part in a Challenge as part of the Leaderboard.
- Specific third parties listed in the table above.
Whenever we transfer your personal data out of the UK and EEA (including to e-Zest Solutions Limited, for technical support purposes), we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data in accordance with the UK GDPR.
- Where we use certain service providers, we may use specific contracts approved in accordance with the UK GDPR.
- Where we use providers based in the US, 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 US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our website or the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 unauthorised way.
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.
We only retain your personal data for as long as you are a user of the App. When you terminate your employment with any Employer making use of the App, we will delete any and all personal data held relating to you upon notification by your Employer. However, by law we have to keep basic information about our users of the App (including Contact, and Identity Data) for six years after they cease using our Services for regulatory purposes.
In some circumstances you can ask us to delete your data: please see the Your legal rights section below for further information.
In some circumstances we will anonymise 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.
Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- 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.
Description of Categories of Personal Data
- Identity Data: first name, last name, username or similar identifier, date of birth*, gender* (*optional fields).
- Contact Data: personal email address* (*optional fields)
- Device Data: includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting and activity data from Apple Health (iOS) and Google Fit (Android) and Fitbit and Garmin and Strava. This includes:
- Daily, weekly, monthly and annual step counts,
- Average daily step counts and average daily distance data;
- Total accumulated step counts and distance data;
- Total accumulated check-in data, if location services are enabled;
- Content Data: includes photos* stored on your Device (*optional)
- Profile Data: includes your username and password, (See Identity Data, above)
- Usage Data: includes details of your use of any of the App or your visits to Our website 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 from us and our third parties and your communication preferences.
- Location Data: includes your current location disclosed by GPS technology when checking in and out of unapproved venues and approved venues, if location services are enabled.
- Health Data: data concerning your health.
- Special Category Data: includes information relating to your health data provided by you to us.
- Activity Data: includes information processed by your device via Apple Health, Google Fit, Fitbit, Garmin or Strava including
- Activity type (cycle, workout, etc);
- Activity time and date (when the activity occurred);
- Activity distance where applicable
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 firstname.lastname@example.org.
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.
The Employer of any of our users, so that they can redeem benefits and offers based upon your usage of the App.