Data Controller: means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed.
Data Processors (or Service Providers): means any natural or legal person who processes Personal Data on behalf of a Data Controller.
Personal Data: means data about a living individual who can be identified from those data (or from those data and other information that is either in our possession or likely to come into our possession). It does not include data where the identity has been removed (anonymous data).
Usage Data: means data about how the Service is accessed and used. This is collected automatically, either generated by the use of the Service or from the service infrastructure itself (for example, the duration of a visit to a particular page).
User: means the individual using the Service.
Data collection and use
We collect several different types of data via the Service and use that data for various purposes.
Types of data collected
When registering for the Service, certain information is mandatory in order to create your account, including your name, email address and information about your NHS Region and Staff Group. Other information requested during the registration process is optional, such as your date of birth, mobile number, ethnicity and gender.
While using the Service, we may also ask you to provide us with certain Personal Data that can be used to contact or identify you. This Personal Data may include things such as your email address, name, address and postal code.
During your use of the Service, we may request data from you relating to the topics covered by the Service; for example, your perceived levels of wellbeing, fitness levels and nutritional awareness.
Feedback or survey data
We may request feedback from you on the performance of the Platform and the content being provided. This will always be an optional submission and any such feedback will remain anonymous.
We may also collect Usage Data. This Usage Data may include information such as your computer's internet protocol address (i.e. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Platform support data
Should you encounter an issue with the Platform, you are invited to submit a support ticket through the Platform which would require your name, email address, a description of the issue and any image uploads.
Tracking & cookies data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Further details about the cookies we use are set out in the Cookie section below.
Purpose of processing
We use the data that we collect for various purposes:
- Registering you as a user of the Service.
- Providing and maintaining the Service.
- Evaluating the effectiveness of the Service.
- Evaluating engagement and retention across all groups.
- Evaluating perceived behaviour change across all groups.
- Improving the Service.
- To provide you with a customised health programme.
- To aid clinical research into movement, health, wellbeing and behaviour change.
- To notify you about changes to our Service.
- To allow you to participate in interactive features of our Service when you choose to do so.
- To provide customer support.
- To monitor the usage of our Service.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about (unless you have opted not to receive such information).
- To detect, prevent and address technical issues.
All email addresses will automatically be added to an automated email distribution list that will only be used for communication from BMF relating only to the Platform and Services. It may include updates on new content, reminders, invitations or other information relating to the Services that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Except for the above, we will not process or report any Personal Data within the Service. We will further continually monitor all data processing and reporting to ensure that, to the extent practicable, all data remains anonymous.
Location of data
BMF processes all data provided by its Users with accounts in the United Kingdom, within the European Economic Area.
All data collected by BMF will be stored in secure hosting facilities provided by Amazon Web services. BMF has a data processing agreement in place with its provider, ensuring compliance with data protection laws.
Retention of data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your country but always within the United Kingdom or European Economic Area.
Disclosure of data
Disclosure for law enforcement. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Security of data
The security of your Personal Data is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Legal basis for processing Personal Data
BMF may process your Personal Data because:
- We need to perform a contract with you.
- You have given us permission to do so.
- The processing is in our legitimate interests and it's not overridden by your rights.
- For payment processing purposes.
- To comply with the law.
Your Data Protection Rights
If you are a resident of UK, you have certain data protection rights. BMF aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at firstname.lastname@example.org.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete your Personal Data.
- The right of rectification. You have the right to have your Personal Data corrected if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
- The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where BMF relied on your consent to process your Personal Data.
Please note that we may ask you to verify your identity before responding to such requests.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to complain to the Information Commissioner’s Office (ICO) (www.ico.org.uk) about our collection and use of your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We may employ third-party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform service-related services or to assist us in analysing how our Service is used.
These third-parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party service providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
- GoCardless to process your direct debit payments. More information on how GoCardless processes your personal data and your data protection rights, including your right to object, is available at https://GoCardless.com/legal/privacy/
Links to other sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service is not intended for use by anyone under the age of 16.
We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your children has provided us with Personal Data, please contact us at email@example.com. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
BMF Data Protection officer
BMF has a “Data Protection Officer” who is responsible for matters related to privacy and data protection. This Data Protection Officer can be reached at the following address:
Address: BMF Human Performance Ltd, Grosvenor Arch, Battersea, SW11 8AB