BetterSpace Website and Application Privacy Policy

Introduction

Trust, transparency and data privacy are core values at BetterSpace. We are committed to safeguarding the privacy of all the individuals we deal with, including:

  • visitors to the BetterSpace website;
  • users of the BetterSpace mobile and web application;
  • the personnel of our customers and prospective customers; and
  • the personnel of our marketplace suppliers, general suppliers and other business partners.

This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

In this policy, “we”, “us” and “our” refer to WellbeingX Limited, the legal name of BetterSpace. For more information about us, see below.

The personal data that we collect

In this section of the policy, we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

We may process data about your use of our website and the BetterSpace application (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems.

We may process information relating to our business communications and business relationships, including communications and relationships with prospective customers, customers, marketplace suppliers, general suppliers and business partners (“communications and relationship data“). The communications and relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer and supplier management systems and any information contained in or relating to communications between us and you, or between us and your employer. It will also include any personal data relating to case studies, quotations, reviews and testimonials that you or your employer provide to us. The source of the relationship data is you and/or your employer. We may also collect communications and relationship data from publicly-available sources, such as the UK Companies House database.

If you are or become a registered user of the BetterSpace application, we will process your application user account data (“account data“). The account data may include your name, email address, gender, date of birth, postcode, income bracket, account creation and modification dates, and application settings and preferences. Some of this data such as date of birth and gender, is optional; other information is required to enable us to provide our services. The account data will be linked to data about your employer. The primary source of the account data is you and/or your employer, although some elements of the account data, such as creation and modification dates, will be generated by our website. When setting up and/or using your BetterSpace account, you may be invited to complete one or more wellbeing questionnaires. You may be asked questions about such matters as sleep, exercise, social connections and goals. You may also be asked to provide information about impairments, health conditions and learning difficulties that have an impact upon your life (“health data“) and about your ethnicity (“ethnicity data“). Any use of health data and ethnicity data is subject to special restrictions set out in this policy.

If you order goods, services or digital products through the BetterSpace application, we will process information relating to the relevant transaction(s) (“transaction data“). The transaction data may include your name, your contact details, wellbeing budget expenditure, personal expenditure and other transaction details. The source of the transaction data is you, our payment services provider and/or the relevant marketplace supplier.

Please do not supply any other person’s personal data to us unless we prompt you to do so.

BetterSpace has not been designed for children to use, and we will delete any personal data that we collect if we know or suspect it relates to a person under 18 years of age.

Purposes of processing and legal bases

In this section of the policy, we have set out the purposes for which we may process personal data and the legal bases of the processing.

Operations – We may process your personal data for the purposes of operating our website and the BetterSpace application, transacting with our customers, enabling our marketplace suppliers to supply their goods, services and digital products, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, application and business generally.

Publications – We may process personal data contained in case studies, quotes, reviews and testimonials that you or your employer provide to us for the purposes of publishing such data on our website and in our application. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.

Relationships and communications – We may process account data (excluding health data and ethnicity data) and communications and relationship data for the purposes of managing our relationships, communicating with you and with our customers, suppliers and business partners (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely the maintenance of our relationships, and the proper administration of our website, application and business generally.

Personalisation – We may process account data (including health data but excluding ethnicity data) and/or usage data for the purposes of personalising the content (including promotional content) that you see in the BetterSpace application through our recommendation engine, to help ensure that you see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience to our application users.

Direct marketing – We may process usage data, communications and relationship data, account data (including health data but excluding ethnicity data) and transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent or (in those cases where we have not asked for your consent) our legitimate interests, namely promoting our business and communicating marketing messages and offers to our application users, customers and prospective customers.

Research and analysis – We may anonymise your personal data and use that anonymised data for the purposes of researching and analysing the use of our website and application, as well as researching and analysing other interactions with our business. The legal basis for the anonymisation process is our legitimate interests, namely monitoring, supporting, improving and securing our website, application and business generally.

Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

Processing of health data – When processing “special categories” of personal data such as health data and ethnicity data, a data controller is obliged to satisfy an additional condition: accordingly, we will only process your health data and ethnicity data with your explicit consent.

Providing your personal data to others

If you are a BetterSpace application user, we may disclose aggregated and anonymised data derived in part from your transaction data and usage data to your employer. In relation to transaction data, we may also disclose specific information about your expenditure upon such goods, services and digital products that does identify you to your employer. Employers may be required to collect such information for tax purposes. Employers will act as independent controllers in relation to any personal data that we may disclose to them. We will never disclose health data or ethnicity data to employers except in aggregated and anonymised form.

If you are a BetterSpace application user and you order goods, services and/or digital products from a BetterSpace marketplace supplier, then we will provide information relating to that order, including relevant transaction data and account data (excluding health data and ethnicity data), to the relevant marketplace supplier. Each marketplace supplier acts as an independent controller with respect to such personal data and, accordingly, the supplier’s use of your personal data will be subject to the supplier’s own privacy policy, which will be made available to you through the BetterSpace platform before the completion of the order. After such an order, we may share further information with the relevant marketplace supplier for the purposes of facilitating the provision of the relevant goods, services and/or digital products.

We may disclose your personal data to our suppliers or subcontractors identified on the suppliers’ page of our website.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

In addition to the specific disclosures of personal data set out in this section of the policy, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Finally, we may disclose your personal data to a purchaser of our business as a going concern or other successor in business.

International transfers of your personal data

In this section of the policy, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.

‌We are based in the UK and most of our own processing of your personal data will happen in the UK.

We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

‌If you are a BetterSpace application user and you order goods, services and/or digital products from a BetterSpace marketplace supplier, then that supplier may transfer your personal data in its own relevant jurisdictions, as detailed in the supplier’s privacy policy.

Details of the jurisdictions in which our general suppliers and subcontractors operate, along with other information about their processing activities, are set out on the suppliers’ page of our website.‌

You acknowledge that personal data that you submit for publication through our website or application, including personal data contained in case studies, quotations, reviews and testimonials, may be available, via the internet, around the world.

Retaining and deleting personal data

This section of the policy sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

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

We will retain your personal data as follows:

  • usage data will be retained for 36 months following the date of collection;
  • communications and relationship data will be retained for a minimum period of 6 years following the date of the final communication between us and the relevant person, and for a maximum period of 7 years following that date;
  • account data (excluding health data and ethnicity data) will be retained for a minimum period of 6 years following the date of closure of the relevant account, and for a maximum period of 7 years following that date;
  • health data and ethnicity data will be deleted or anonymised within 30 days following the date of closure of the relevant user account; and
  • transaction data will be retained for a minimum period of 6 years following the date of the transaction, and for a maximum period of 7 years following that date.

If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified above in accordance with the applicable licence terms, subject to your data subject rights.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

Security of personal data

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

We will store your personal data on secure cloud servers. We may also store limited personal data on secure personal computers and mobile devices and in secure manual record-keeping systems. 

Where appropriate, personal data will be stored in encrypted form; and for the avoidance of doubt, all health data and ethnicity data will be stored in encrypted form.

Data 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.

‌Our software, network and security systems and policies are regularity subject to third party audit and review.

You should ensure that your password for the BetterSpace application 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).

Your rights

In this section of the policy, we have listed the rights that you have under data protection law.

Your principal rights under data protection law are:

  • the right to access – you can ask for copies of your personal data;
  • the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
  • the right to erasure – you can ask us to erase your personal data;
  • the right to restrict processing – you can ask us to restrict the processing of your personal data;
  • the right to object to processing – you can object to the processing of your personal data;
  • the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
  • the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
  • the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting: https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en

and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

Third party websites and services

Our website and the BetterSpace application include hyperlinks to, and details of, third party websites.

We do audit or review the marketplace suppliers that feature in the BetterSpace application. However, notwithstanding any audit or review process, we have no direct control over, and are not responsible for, the privacy policies and practices of the marketplace suppliers or any other third parties.

Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

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

Cookies we use

We may use cookies for the following purposes in relation to our website and/or application:

  • personalisation – we use cookies to store information about your preferences and to personalise the BetterSpace application for you;
  • advertising and promotions – we may use cookies to help us to display advertisements and promotions that will be relevant to you; and

cookie consent – we use cookies to store your preferences in relation to our use of cookies.

Cookies used by our service providers

We use Google Analytics to gather information about the use of our website and the BetterSpace application by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

Our website sends data to our HubSpot customer relationship management system and we use HubSpot to help us understand the use of our website. HubSpot uses both persistent and session cookies to gather information about visitors to our website. For more information, see: https://knowledge.hubspot.com/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser.

We have integrated certain Twitter services into our website, and we use Twitter to help us understand the use of our website. Twitter uses persistent cookies to gather information about visitors to our website.  For more information, see: https://twitter.com/en/privacy.

We have integrated certain LinkedIn services into our website, and we use LinkedIn to help us understand the use of our website. LinkedIn also uses both persistent and session cookies to gather information about visitors to our website.  For more information, see: https://www.linkedin.com/legal/cookie-policy

We use Vimeo for embedding videos in our website, and Vimeo uses session cookies to enable the embedded video player functionality. You can find out more about Vimeo’s use of cookies at https://vimeo.com/cookie_policy.

Our payment services provider, Stripe, uses cookies for fraud detection and prevention. Find out about Stripe’s cookie use at https://stripe.com/cookies-policy/legal

Local storage

Cookies are one example of “web storage”.

We also use another form of web storage, known as “local storage”. We use local storage for the purposes of authentication and status: to identify you when you visit or login to our application and as you navigate the application, and to help us determine if you are logged into our application.

Managing cookies and local storage

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.

If you block cookies, you will not be able to use all the features on our website or in our application.

You can clear local storage by clearing your browser cache.

Amendments

We may update this policy from time to time by publishing a new version on our website and in the BetterSpace application.

Our details and data protection officer

Although we trade under the name BetterSpace, our legal name is WellbeingX Limited.

We are registered in England and Wales under registration number 11053000 and our registered office is at The Willow House, The Ridings, Headington, Oxford, England, OX3 8TB.

If you would like to contact us regarding data protection matters, please write to our data protection officer, Alfredo Belfiori, in the first instance, using: dataprotection@betterspace.uk.

You can also contact us:

  • by post, to the postal address given above;
  • using our contact forms;
  • by telephone, on the contact number published on our website and through our application; or
  • by email, using the email address published on our website and through our application.

Data protection registration

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

Our data protection registration number is ZA508353.


Published on 9th Februray 2021