OpenMind

OpenMind Privacy Notice

Last Modified: 19 December 2019, version 5.0, Prepared by LinkiLaw and Ash Dey (Founder)

 

When you use OpenMind Wellbeing Limited, you trust us with your information. We are committed to keeping that trust. That starts with helping you understand our privacy practices.

This policy describes the information OpenMind Wellbeing Limited uses, maintains and discloses information collected, and your choices regarding this information.

OpenMind Wellbeing processes your personal data under a legitimate interest basis for the purpose of fulfilling the services delivered and improving the experience.

In this policy, we use simple language to help you understand our privacy practices.

“we“, “us”, “our” and “OpenMind Wellbeing “refer to “OpenMind Wellbeing Limited”.

“users”, “wellbeing professionals”, “employers” and “employees” refer to “Users” of the OpenMind Wellbeing Limited website or services.

The policy applies to all “Users” of OpenMind Wellbeing Limited’s services.

Data Protection Registration

We are registered as a data controller with the UK Information Commissioner’s Office (ICO).

Our data protection registration number with the ICO is ZA474101

Our data protection officers contact details are:

The website openmindwellbeing.com is owned and operated by OpenMind Wellbeing Limited.

We are registered in England and Wales under registration number 1152779, and our registered office is at 43 Rookery Court, 80 Ruckholt Road, London, E10 5FA.

Contact us via our website or email connect@openmindwellbeing.com.

 

The Information We Collect
We are acting as a data controller with respect to the personal information of our website visitors and service users.

 

OpenMind Wellbeing collects:

  1. Information that you provide on User profile creation whether a wellbeing professional, employer or employee.
  2. Information created when you use our services, including website generated information
  3. Information from other sources, Such as third-party partners, e.g. equipment rental or resellers agreements, validation of background information

The legal basis for this information processing is our legitimate interests, namely monitoring, improving our website, services delivered, marketing and IT security.

We are committed to safeguarding the privacy of our website visitors and service users.

The following information is collected by us:

1.  Information that you provide may include:

  • User profile / account information: We collect information when you create or update your account. This may include your name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), location, photo and personal biography.
 
  • Background check information: Quality and safety are key priorities for us. For “wellbeing professionals” we collect additional information including insurance documents, certifications related to any professional bodies they may be accredited to for background checks and vetting processes for services offered. Where customers, ’employers’, require further assurances and vetting by law, we will work with all parties to ensure the requirements are met before services are offered.
 
  • Demographic data: We may collect demographic information about you to allow us to provide local services, including through user surveys.
 
  • User generated content: We may collect information that you submit when you provide feedback, ratings or compliments for other users, when contacting us. This is for use of improving the quality of the service delivered.
 
 2. Information created when you use our services, may include:
 
  • Services Used: We collect information about how you interact with our services, including information such as service provided, or services booked, specific wellbeing professionals, time and dates. The is to allow us to improve the quality of the service provided.
 
  • Location: We collect information with regards to where services are to be delivered / received in relation to our users. The is to allow us to improve the quality and availability of the service provided.
 
  • Transaction information: We collect transaction details related to your use of our services, including the type of services you requested or provided, your order details, delivery information, date and time the service was provided, amount charged, distance travelled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
 
  • Website usage & device information: We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, and mobile network information. Access dates and times of the website, pages viewed, and website navigation paths, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies and similar technologies that create and maintain unique identifiers. The is information is collected to allow us to improve the quality of the services provided, improve our website and ensure adequate IT Security.
 
  • Communications information: We enable users to communicate with each other and OpenMind Wellbeing through the websites and other services. For example, we enable wellbeing professionals and workplaces to communicate via sharing of agreed contact information, the purpose maybe for additional information or planning when arranging an activity. We may also use this information for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services and for analytics.
 
 3. Information from other sources, may include:
 
  • User feedback, such as ratings or compliments.
  • Users providing your information in connection with referral programs.
  • Users requesting services for or on your behalf.
  • Users or others providing information in connection with claims or disputes.
  • Professional bodies (used for vetting of wellbeing professional, for example the Yoga Alliance Professionals, British Wheel of Yoga,UK Network for Mindfulness-Based Teacher Training Organisations, UK Mindfulness Network )
  • Delivery partners, (for example, mat rental or purchasing equipment via us to a third-party supplier).
  • Financial services providers (if you are a wellbeing partner or delivery partner).
  • Publicly available sources.
  • Marketing service providers.

OpenMind Wellbeing may combine the information collected from these sources with other information in its possession. Our website and services are targeted at persons over the age of 16. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data. In certain circumstances, for example community sessions or when providing activities in school environments where participants may be under this age, agreements and safety checks will be made with the responsible guardians.

How We Use Your Information

OpenMind Wellbeing collects and uses information to enable reliable and convenient service management, delivery.

We also use the information we collect:

  • To enhance the safety, quality and security of our users and services
  • For customer support
  • For research and development
  • To enable communications to or between users
  • To provide promotions or contests
  • In connection with legal proceedings
  • OpenMind Wellbeing does not sell or share your personal information to third parties for third party direct marketing purposes.

The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, OpenMind Wellbeing processes the information of EU users based on one or more of the grounds specified under the GDPR.

OpenMind Wellbeing uses the information it collects for purposes including:

1.  Providing services and features: We use the information we collect to provide, personalise, maintain and improve our products and services. This includes using the information to:

  • Create and update your account.
  • Verify your identity.
  • Enable service delivery. This includes automated processing of your information to enable quick management capabilities on the website.
  • Process or facilitate payments for those services.
  • To track the progress of service delivery, from initial request through to collecting/ providing feedback and reports.
  • Enable features that allow you to share information with other people, such as when you submit a compliment or rating for a wellbeing professional, refer a friend, sharing event details with other potential users internal to you or publicly on social media.
  • Enable features to personalise your OpenMind Wellbeing account, such as creating, enable quick access to previous bookings.
  • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, research, monitor and analyse usage and activity trends.
2.  Safety and security: We may use your data to help maintain the safety, security and integrity of our services and users.  This includes, for example:
 
  • Vetting wellbeing professionals against service offerings. We use your data provided to check against certification held, insurance, registration with professional bodies (if applicable). If services are to be delivered in sensitive environments, such as schools – further vetting will be conducted to ensure requirements customer and local law are met.
3.  Customer support: We may use the information we collect to assist you when you contact our customer support services, including to:
 
  • Direct your questions to the appropriate customer support person
  • Investigate and address your concerns
  • Monitor and improve our customer support responses
4.  Research and development: We may use the information we collect for testing, research, analysis and product development.  This allows us to improve and enhance the safety, quality and security of our services, develop new features and products, and finance solutions in connection with our services.
 
5.  Communications among users: We may use the information we collect to enable communications between our users.  For example, a wellbeing professional and key contact in a workplace hosting the activity.
 
6.  Communications from OpenMind Wellbeing: We may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events.  This will be based on the privacy controls you have accepted.
 
7.  Legal proceedings and requirements: We may use the information we collect to investigate or address claims or disputes relating to your use of our services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
Privacy Controls, Cookies and Third Party Technologies

OpenMind Wellbeing uses privacy controls, cookies and other identification technologies on our website, emails, and online ads for purposes described in this policy.

Privacy Controls

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls on marketing material this can be managed via mailchimp. In the roadmap for OpenMind Wellbeing these will be made available via the platform. When this feature is available notification will be given to users.

Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We will ask you to consent to our use of cookies when you first visit our website.

OpenMind Wellbeing uses cookies and similar technologies for purposes such as:

  • Authenticating users
  • Remembering user preferences and settings
  • Determining the popularity of content
  • Delivering and measuring the effectiveness of advertising campaigns
  • Analysing site traffic and trends, and generally understanding the online behaviours and interests of people who interact with our services We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services.

Cookies used by our Service Providers and Third-party websites

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at:https://www.google.com/policies/privacy/

We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com/you can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org.However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser you opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites, including OpenMind Wellbeing.

Information Sharing and Disclosure

Some of OpenMind Wellbeing’s products, services and features require that we share information with other users or at your request.

OpenMind Wellbeing may share the information we collect as described:

1.  With other users:

  • For example, where the users are a wellbeing professional and workplace employer booking services
  • For example, between workplace employers and workplace employees when communicating sessions and driving engagement.
  • For example, the workplace employer will have visibility of their employees using the platform.
2.  At your request:

  • Other people at your request. For example, sharing via email templates, social media that you are attending an event and want to encourage others.
  • OpenMind Wellbeing partners. For example, equipment (mat) rental, resellers agreement on equipment.
3.  With the public when you submit content to a public forum:

  • We love hearing from our users — including through public forums such as blogs, social media, and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.
  • It is your responsibility not to submit personal information on these public forums.
4.  With OpenMind Wellbeing service providers and business partners:  We may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:

  • Payment processors and facilitators.
  • Background check for wellbeing professionals
  • Cloud storage providers.
  • Marketing partners and marketing platform providers.
  • Data analytics providers.
  • Research partners, including those performing surveys or research projects
  • Vendors that assist us to enhance the safety and security of technology
  • Consultants, lawyers, accountants and other professional service providers.
  • Equipment resellers or rental services (on your request only)

5.  Data & information hosting: We make sure the data we collect from you will be transferred to and store din regions that are deemed adequate by the European Commission.  The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries.  Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

6.  For legal reasons or in the even of a dispute: We may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

7.  With consent: We may share your information other than as described in this policy if we notify you and you consent to the sharing.

Information Retention and Deletion

OpenMind Wellbeing retains user profile and other information for as long as you maintain your OpenMind Wellbeing account.

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We require user profile information in order to provide its services and retains such information for as long you maintain your OpenMind Wellbeing account.

We retain certain information, including transaction, location, device and usage information, for a maximum of 5 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates, following the date you unsubscribe from our website. Once such information is no longer necessary for providing OpenMind Wellbeings’ services, enable customer support, enhance the user experience or other operational purposes, we take steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection. OpenMind Wellbeing thereafter deletes or anonymises such information in accordance with applicable laws.

You may request deletion of your account at any time through contacting us connect@openmindwellbeing.com , in futures versions of the OpenMind Wellbeing website/ platform we will make the addition of inbuilt privacy controls, when this is done we will notify users.

Following such request, OpenMind Wellbeing deletes the information that it is not required to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above.

We may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security.

Choice and Transparency

OpenMind Wellbeing provides means for you to see and control the information that we collect You may also request that OpenMind Wellbeing provide you with explanation, copies or correction of your data.

You may also request that OpenMind Wellbeing provide you with explanation, copies or correction of your data.

OpenMind Wellbeing will take appropriate technical and organisational precautions to secure your personal data / information and to prevent the loss, misuse or alteration of your personal information.

Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority;
  • and the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.OpenMind Wellbeing provides means for you to see and control the information that we collect.

1.  Privacy settings: Privacy settings can currently be updated on request via connect@openmindwellbeing.com, in future versions of the OpenMind platform we will include under settings, this will give users the ability to set or update their personal details and sharing preferences, and their preferences for receiving email notifications from us.

2.  Ratings look-up: After every activity hosted, all user groups (the wellbeing professional, the employer and employees) may be able to rate each other, as well as give feedback on how the event went.  This two-way system holds everyone accountable for their behaviour.  Accountability helps create a respectful, safe environment for both workplaces and wellbeing professionals.

Your given ratings, and those received will be visible for you to see, or can be requested, connect@openmindwellbeing.com.

3.  Explanations, copies and corrections: You may request that OpenMind Wellbeing:

  • Provide a detailed explanation regarding the information OpenMind Wellbeing has collected about you and how it uses that information.
  • Receive a copy of the information OpenMind Wellbeing has collected about you.
  • Request correction of any inaccurate information that OpenMind Wellbeing has about you.

You can make these requests by contacting OpenMind Wellbeing, connect@openmindwellbeing.com.

4.  Marketing opt-outs: You may opt out of receiving promotional emails from OpenMind Wellbeing using the instructions at the bottom of marketing material received, using the Mailchimp options.  You may also opt out of receiving emails and other messages from OpenMind Wellbeing by following the instructions in those messages received.

5.  Deletion: Users may request deletion of their accounts at any time.  Users may request deletion by contacting us,  connect@openmindwellbeing.com.

You may also submit questions, comments or complaints to OpenMind Wellbeing Data Protection Controller.

Security

OpenMind Wellbeing will take appropriate technical and organisational precautions to secure your personal data / information and to prevent the loss, misuse or alteration of your personal information.

We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

Acknowledgment that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

Updates to This Policy

We may occasionally update this policy.

We may occasionally update this policy. If we make significant changes, we will notify you of the changes through email or through others means, via the website. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy.

We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review, on request.