Privacy Policy

Privacy Policy

Privacy Policy

This was last updated 25.10.2021

The Tri Wellness App is a trading name of Tri Wellness Ltd, (referred to as either “Tri Wellness”, “The Tri App”, “we”, “us” or “our” in this Privacy Policy). We recognize that privacy is important. While no data transmission over the Internet is 100% secure from intrusion, we have used and will continue to use commercially reasonable efforts to ensure the protection of your confidential information.

What does this Privacy Policy Cover?

We want to be transparent with you about how we collect and use your Personal Data in making available our platform, and "website" and tell you about your privacy rights and how the law protects you. With that in mind, this Privacy Policy is designed to describe:

• Who we are and how to contact us
• Your rights relating to your Personal Data
• Marketing communications preferences
• What Personal Data we collect
• How we use your Personal Data and why
• What happens when you do not provide necessary Personal Data?
• Personal Data from Third Party Sources
• How we use cookies and other tracking or profiling technologies
• Who we share your Personal Data with
• How we keep your Personal Data secure
• How long we store your Personal Data
• Our policy on children
• Third party links

This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of this website, including any data you may provide through this website.

The Privacy Policy is intended to meet our duties of transparency under the “General Data Protection Regulation” or “GDPR”. We will post any modifications or changes to this Privacy Policy on this page.

Your personal data – what is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the GDPR)

Who are we?

Tri Wellness Ltd is the data controller and this means that it decides how your personal data is processed and for what purposes, to act on your rights. You can speak to us at any time using our Consent Details below. To exercise all relevant rights, queries or complaints please contact our Data Protection Officer the first instance by email admin@triwellness.co.uk.



Exercising your Rights

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at :- admin@triwellness.co.uk

We will reply to your complaint as soon as we can.


Your rights relating to your Personal Data

Your rights under the General Data Protection Regulations 2016

The right to be informed

You have the right to be informed about what data is being collected, how and why it is being used and any 3rd parties that rely on the information.

The right of access

You may request details of personal information which we hold about you.

The right to rectification

If you believe that any information we are holding on you is incorrect or incomplete, please email or write to us as soon as possible. We will promptly correct any information found to be incorrect.

The right to erasure

Where the data we hold is not required for legal or medical record keeping you may request that it is erased.

The right to restrict processing

If you believe the data we are processing is incorrect you may request that the data is no longer processed until corrected.

The right to data portability

You may request that the data you have provided be transferred to another data controller in a machine readable format.

The right to object

You have the right to object to the processing of your data.

Rights in relation to automated decision-making and profiling are not currently utilised by our client services.

Further information can be obtained from the Information Commissioners Office website https://ico.org.uk

You can contact the Information Commissioners Office help line on 0303 123 1113

Marketing communications preferences

If you sign up to receive email newsletters or promotional materials from us we will use the information you give us to provide the communications you have requested.

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. If you no longer wish to receive push notifications, you may turn them off at the device level.

Where you opt out of receiving these marketing messages, this will not apply to service correspondence which help you administer your account and allows us to update you when our website changes or you receive notifications on your account.

What Personal Data we collect

All the Personal Data we collect, both from you and from third parties about you, is outlined below.


Before you continue, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it relates to: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific website feature, or to understand whether and how use of our website may enhance your mood.

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.

We only share Aggregated Data (i.e. anonymous data) with your employer(s) – for instance, they will be able to see whether their workforce is overall happy or when there are periods of stress, and whether use of the website is beneficial for their employees’ wellbeing. Your employer(s) will not have access to the data on your Tri App account or any User Generated Data.

We also use such Aggregated Data to understand our end-users, to develop the Tri Wellness App offering and to share the data with health professionals and researchers.

Special Categories of Personal Data

Through our website, and the services we offer, we may collect some “Special Categories of Personal Data” about you, if you provide such data in your User Generated Data.

Special Categories of Personal Data are data that include details about your race or ethnicity, age and sex, Since you are able to upload details of your mood or mental state on the website (e.g. through the Happiness and Stress measures options), the data you provide us may contain data relating to your health or other Special Categories of Personal Data.

With your consent, we share Aggregated Data that may include Special Categories of Personal Data with your employer(s), as further described in the “Aggregated Data” section above.

We do not share any of your Personal Data (including any Special Categories of Personal Data) with your employer.

We do not collect any information about criminal convictions and offences.

How we use your Personal Data and why

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal
bases:

• Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

Different grounds than those set out above are required by the GDPR to allow us to process your Special Categories of Personal Data. Most commonly, we will rely on one of the following grounds:

• Where the processing is necessary to enable you to exercise your right to work in a safe workplace and to enable your employer’s reciprocal duty to provide a safe workplace to their employees (“Employment Ground”).

• Where the processing is necessary for the purposes of preventive or occupational medicine, the assessment of the working capacity of employees, medical diagnosis, the provision of health or social care or treatment, or pursuant to a contract with a health professional (“Healthcare Ground”). We will only rely upon the Healthcare Ground where the processing is done by, or under the responsibility of, a clinical psychologist (or other mental health professional subject to obligations of professional secrecy) and in accordance with English laws and/or rules established by a national competent body.
• Where the processing is necessary for scientific research or statistical purposes, as further explained in the “Aggregated Data” section above (“Research Ground”). We will always ensure your Personal Data is anonymised when using it for research purposes.
• Where we have your explicit and specific consent to carry out the processing for the Purpose in question (“Explicit Consent”).

Generally, we do not rely on your Consent (or Explicit Consent) as a legal basis for using your Personal Data (including your Special Categories of Personal Data) other than in the context of direct marketing communications.

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionality of the website).

In this case, we may have to stop you from using our website with us but we will notify you if this is the case at the time.

Who we share your Personal Data with

We only share personal information with other companies or individuals in the following limited
circumstances:

• We have your consent.

• Sharing the information with our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:

(a) satisfy any applicable law, regulation, legal process or enforceable governmental request,

(b) enforce applicable Terms of Service, including investigation of potential violations thereof,

(c) detect, prevent, or otherwise address fraud, security or technical issues, or

(d) protect against harm to rights, property or safety, of our users, us or the public as required or permitted by law.


• We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users by demographic. Such information does not identify you individually.


Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain aspects of your Personal Data from third party sources.

How we keep your Personal Data secure

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data

We keep data in accordance with Guide to Data Protection – Principle 5 Retaining Personal Data, we retain all records while you have on-going services with us, if you do not have any services with us your data may be held for a period of up to 2 years. Unless a longer retention period is required by law (for example for regulatory purposes).

Cookies - What are they?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

• first party cookies, served directly by us to your computer or mobile device; and • third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Google Analytics

We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about which pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.


You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.com/intl/en_uk/analytics/privacyoverview.html

• We use Google Analytics to analyse the use of our website.

• Our analytics service provider generates statistical and other information about website use by means of cookies.

• The analytics cookies used by our website have the following names: [_ga, _gid, _gat, AMP_TOKEN, _gav_, __utma, __utmt, __utmb, __utmc, __utmz, __utmv].

• The information generated relating to our website is used to create reports about the use of our website.

• Our analytics service provider’s privacy policy is available at http://www.google.com/policies/privacy/.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit”
facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our website.
For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our website.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.


Local Storage

We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on the website may also use HTML5 to collect and store information.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile phone. This software may record information such as how often you use the Site, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.

Log Files

As true of most websites, we gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

If you receive the HTML-formatted version of our emails, your opening of the email is notified to us and saved. Your clicks on links in the emails are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.

Third party links

This website may include links to third-party websites, plug-ins and applications.

Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Support

Working hard to keep our services always online and up to date is more than just our job. It’s who we are and part of our core values. We strive to ensure the highest level of continuity throughout all our the services we provide.


Social Media

Our app/website does include social media sharing buttons to 3rd party sites such as Facebook, Twitter, Instagram
Google+ and LinkedIn, which may set 3rd party cookies. Please refer to
Google+ these sites’ individual privacy
policies for further information.

Our policy on children

This website is not intended for children below 16 and we do not knowingly collect data relating to such children.



 

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