Wellbeing Associates Privacy Policy

Effective: July 2020 

IMPORTANT NOTICE

At Wellbeing Associates, our mission is to 

empower your teams to complete their autism assessments in less than half the time.

Each assessment is stripped of personally identifiable information, then used to research Autism trends among different demographics, “age, gender, city, etc.” Our mission covers our offline and in-store activities, and extends to our online community as well through our websites, applications, and connected products and services (which we collectively refer to in this Privacy Policy as the “Services”). Our Privacy Policy describes how we collect and process your Personal Data through our websites (e.g., including, but not limited to, wellbeing.associates, wellbeingcv.co.uk (“Websites”)), corresponding Mobile Apps, in store, at events and on campus. We encourage you to read this Privacy Policy as well as our Terms and Conditions of Use(referred to throughout as our “Terms”).

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AND United Kingdom AS DESCRIBED IN THIS PRIVACY POLICY. END USERS FROM OUTSIDE THE US AND UK ARE ENCOURAGED TO Read More

Note to Residents of the European Union: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR. Further country/region specific information for our European consumers and users is outlined in the Location-Specific Disclosures section.

Who We Are 

We are WellbeingCV Limited, doing business as Wellbeing Associates (collectively referred to herein as “Wellbeing Associates,” “we,” “us,” or “our”). We provide Internet and mobile app-based services including, for example, the apps linked to below (“Mobile Apps”):

  • Autism Mapper

  • Autism Platform

We also provide autism assessment services via Express Clinics. 

How We Collect and Use Personal Data 

We collect your Personal Data in a number of ways and for various purposes, including:

  1. When you register for an account or interact with our Services. Read More

  2. When you input Data within our Services or use our Services that collect or infer such data from mobile device sensors. Read More

  3. When you use or interact with a wearable or other connected device. Read More

  4. When you give us permission to collect Location Data. Read More

  5. When you communicate with us or sign up for promotional materials. Read More

  6. When you participate in special activities, offers, or programs. Read More

  7. When you engage with our online communities or advertising. Read More

  8. When you access third party products and services. Read More

  9. When you connect with us through social media. Read More

  10. When we collect data from third parties or publicly-available sources. Read More

  11. When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies. Read More

  12. When we aggregate or centralize data. Read More

  13. When we link you to friends across platforms. Read More

  14. When you take assessments; share content or achievements; or invite friends. Read More

  15. When we provide you geographically relevant Services, offers, or advertising. Read More

  16. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes ( Location-Specific Disclosures may apply). Read More

The legal basis for processing your information

Wellbeing Associates relies on several different legal basis depending on the processing being performed:

(Article 6(1)(a)), Consent – on specific occasions Wellbeing Associates will only process certain data if you consent e.g. on registration you only need to provide certain “special categories” of data if you agree that that.

(Article 6 (1)(b)), necessary for the performance of your student contract – on many occasions Wellbeing Associates will process your data to enable it to meet its commitments to you e.g. those relating to education and assessment.

(Article 6 (1)(c)), necessary to comply with a legal obligation – Wellbeing Associates may have legal obligations to provide your personal data to others e.g. HESA.

(Article 6 (1)(d)), for the purpose of protecting the vital interest of yourself or another – sometimes in extreme circumstances Wellbeing Associates will have to release information to protect your interests or the interests of others e.g. in medical emergencies.

(Article 6 (1)(e)), processing necessary for the performance of a task carried in the public interest – Wellbeing Associates is an educational and research establishment and in particular its educational and research activity is conducted in a public interest (including your interest and the interest of others).

(Article 6 (1)(f)), processing is necessary for the purposes of the legitimate interest of Wellbeing Associates or a third party subject to overridden interests of the data subject – Wellbeing Associates (and sometimes third parties) has a broad legitimate interest in activities that connect to the activities and education of students. Subject to those interests not being overridden by the interests of fundamental rights and freedoms of students, it will pursue those interests.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which it is collected.

How We Disclose Personal Data 

We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy, in the Location-Specific Disclosures section, and in the following ways:

  1. To Affiliates and Partners Read More

  2. To Service Providers and Vendors. Read More

  3. To Social Network Providers. Read More

  4. To other Users/Wellbeing Associates Registered Users. Read More

  5. For Advertising and Marketing. Read More

  6. For Certain Analytics and Improvement Read More

  7. For Interest-Based Advertising. Read More

  8. For Legal Compliance, Law Enforcement, and Public Safety Purposes (Location-Specific Disclosures may apply).Read More

  9. In the event of an actual or contemplated sale. (Location-Specific Disclosures may apply). Read More

A list of types of companies with whom we share data is available here.

Data retention

Wellbeing Associates retains personal information it collects from you where there is an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When there is no ongoing legitimate business need to process your personal information, Wellbeing Associates will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then Wellbeing Associates will securely store your personal information and isolate it from any further processing until deletion is possible.

Managing Preferences and Withdrawing Consent 

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Depending on the Service, collection and use of Personal Data may be required for the Services to work. 

We provide you several ways to manage your preferences: 

  • Cookie Use and Controls Read More

  • IP Address Use Read More

  • Web Pixels or Beacons Use Read More

  • HTML5 Local Storage Read More

  • Flash Cookie Use Read More

  • Social Network Interaction and Widgets Read More

  • Mobile Device Advertising IDs, Location, Sensor Data, and In-Range Device Data Use Read More

  • Withdraw Your Consent for Use of Your Mobile Device IDs and Location Data for Analytics and Advertising Read More

  • Other Ways to Manage Your Location Services Read More

  • Change Consent Settings for Communication Preferences Read More

Your rights

You have rights to your personal data held by Wellbeing Associates as set out in the GDPR. These include:

  • Rights to access your personal data to be provided by Wellbeing Associates within one calendar month – known as a Subject Access Requests (Article 15). This includes information on: 

    • A description of your data

    • The Recipients of your data

    • A copy of your data

  • Rights to rectification and erasure. You have the right to correct any inaccurate personal data held by Wellbeing Associates. Once information Wellbeing Associates has collected is no longer necessary for the purpose for which it was collected and processed, you sometimes have the right to have your data erased.

  • Rights to restriction of processing 

    • You sometimes have the right to restrict the processing of your personal data or object to the processing of your data.

    • If you wish to withdraw consent for the processing of your personal data or otherwise restrict or object to the processing of your personal data please contact the Information Compliance Team.

  • Rights to data portability. You have the right to receive your personal data Wellbeing Associates holds in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from Wellbeing Associates.

Changes to this notice

Wellbeing Associates may amend this privacy notice and will occasionally update to reflect customer feedback and enhance its accessibility.

In that case, Wellbeing Associates will post notice of the change on its website and you will be deemed to have accepted such changes.

Wellbeing Associates encourages you to periodically review this notice to be informed of how the institution is protecting your privacy.

Contact details

As a public body Wellbeing Associates has appointed __ as the Data Protection Officer (DPO). Should you have any concerns about your personal data at Wellbeing Associates please contact the DPO by email via:

dpo@wellbeing.associates

Additional guidance can be sought from the Information Governance team:
dataprotection@wellbeing.associates