2.7 As part of the process of using the RR Platform to access the RR Services, We may also collect the following types of Personal Data about You (as applicable):
- Your visits to the RR Platform and the RR Content that You download;
- Information about Your computer (including Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and RR Platform navigation);
- Any other information that You choose to send to us, including any request for further services, general correspondence, and reports of a problem with the RR Platform or the RR Services.
2.8 RR agrees and warrants that it will adhere to all Data Protection Law and will take appropriate technical and organisational security measures against the unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to Personal Data.
2.9 RR shall process Personal Data only to the extent, and in such a manner, as is necessary for the sole purpose of fulfilling the RR Services (including making improvements to the RR Services). For the avoidance of doubt, RR is the exclusive owner of the RR Platform and the RR Content (as defined), however there will be multiple Data Controllers in common (the Customer of RR and the RR Agents, known as our ‘RR Partners’) who may process Your Personal Data as well as any Party Content (as applicable) in order to enable us and them (as Your local authority, NHS organisation, third sector organisation or housing association etc.) to provide You with the best available service.
3. HOW IS THE INFORMATION USED?
3.1 You hereby expressly consent to Your Personal Data being passed on to third party service providers for the sole purpose of RR fulfilling the RR Services only (including making improvements to the RR Services) and not for the purposes of those third parties making marketing communications to You (‘RR Service Providers’).
3.2 You are under no obligation to provide Your Personal Data to the RR Platform, however, if You choose not to, some of the RR Services may not be available to You.
3.3 Where You are a RR End User, it is important to know that RR provides the RR Platform to various RR Partners (and the Secondary Authorised Users of the RR Partners i.e. those who promote the RR Platform on behalf of the Customer or RR Agent who shall be Data Processors). The RR Partners and RR (who all act in the capacity of Data Controllers in common) may share Your Personal Data with each other subject to:
- the disclosure settings of the relevant RR Partner on the RR Platform; and,
- Your express consent being given when You register on the RR Platform.
3.4 You acknowledge that Your Personal Data may be used by RR to contact You by post, phone or by Electronic Mail when necessary in connection with Your use of the RR Platform to access the RR Services e.g. in respect of a change to any of our legal terms and conditions to which You are subject. Electronic Mail: includes email, text, video, voicemail, picture and answerphone messages (including push notifications and in-app notifications).
3.5 From time to time, where You are a RR End User, RR may contact You by Electronic Mail (or by telephone) by way of sending You various confirmations, notifications, feedback requests or any other newsletter or information or offers regarding upcoming RR promotions, services or surveys (including RR Notices). If You change Your mind, You can opt out of receiving some but not all of this as some are required as a necessary part of You continuing to receive access to the RR Services.
3.6 You can opt out of receiving direct marketing communications from RR as described below.
3.7 Any Personal Data that is held with RR shall be retained in accordance with the Data Protection Law. Any Personal Data that is shared as between RR and a RR Partner shall be shared in accordance with a Data Sharing & Use Policy agreed between RR and its RR Customer.
3.8 If Personal Data has been passed to third parties with Your consent, You may need to contact them separately if You change Your mind in relation to their use of Your Personal Data.
RR END USER
OPTING OUT FROM RECEIVING MARKETING COMMUNICATIONS FROM RR (OR A RR PARTNER):
If You do not wish to be contacted in respect of future marketing communications, We will give You the opportunity to unsubscribe to the receipt of such communications in every Electronic Mail communication that is sent to You (or shall procure that any of our RR Service Providers such as Mailchimp and/ or Intercom shall do the same). Alternatively, and additionally, You can contact RR by sending an email to firstname.lastname@example.org with “UNSUBSCRIBE REQUEST” in the subject line or send Your request to the contact address below.
RR AUTHORISED USER
OPTING OUT FROM RECEIVING MARKETING COMMUNICATIONS FROM RR:
If You do not wish to be contacted in respect of future marketing communications, We will give You the opportunity to unsubscribe to the receipt of such communications in every Electronic Mail communication that is sent to You.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA?
4.1 To minimise the risk of unauthorised access to Your Personal Data, We use some of Your Personal Data to authenticate You when using the RR Platform to access the RR Services.
4.2 For our daily operations, We may use RR Service Providers to provide some of our business and operational functions. Consequently, We may need to disclose Your information to them.
4.3 Disclosure of Your Personal Data in Compliance with Laws
You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with RR or with a RR End User or RR Authorised User via the RR Platform, or to protect the rights, property or safety of RR, RR End Users, RR Authorised Users or other third parties.
.4 Transfer of Your Personal Data outside of the European Economic Area (EEA)
From time to time, We may transfer Your Personal Data to a related company, agent or contractor in order to improve our RR Services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Personal Data to such companies for the purposes set out here in accordance with this RR Privacy Statement and as permitted by Data Protection Law from time to time. RR agrees and warrants that it shall pay due regards to all Data Protection Law when effecting, if any, intra-transfer processing of Personal Data that may be carried out within and between RR and either its subsidiaries, affiliates or third party partners. You should be aware that in territories outside the EEA, laws and practices relating to the protection of Personal Data are likely to be different and in some cases may be weaker than those within the EEA. We comply with the safeguards to protect your Personal Data required by law.
4.5 Transfer of Personal Data in the Event of the Sale of Health2Works Limited or its Assets
In the event that Health2Works Limited is sold or transfers some of its assets to another party such as the RR Platform, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this RR Privacy Statement. Your Personal Data will be passed on to a successor in interest in the event of a liquidation or administration of Health2Works Limited.
4.6 Other Sites and their Privacy Policies and Cookie Policies
he RR Platform may contain links to other websites or applications. RR is not responsible for the privacy practices or the content of such websites or applications or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those policies independently.
5. HOW DO WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?
5.1 The privacy and protection of Your Personal Data is important to us. Any RR Member statistics that We may collect and may provide to prospective RR Service Providers, other selected third parties including universities and other research based bodies/ organisations or prospective RR Partners regarding Your usage of the RR Services are provided in anonymised and aggregate form and do not include any individually identifiable data. It is used primarily to aid the technical administration of the RR Platform, to better understand how the RR Platform is functioning, to draw conclusions upon demographic information and various patterns of use and to aid innovation and research, which shall include but shall not be limited to, research in to improvements to standards.
5.2 Although We will do our best to protect your Personal Data, You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Personal Data, We cannot ensure or warrant the security of any Personal Data You transmit to us via, to, or from the RR Platform. Once We have received your information, We will use procedures and security features to try to prevent unauthorised access. How long We keep Your Personal Data collected through the RR Platform depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. We may send You direct marketing communications for as long as You do not opt-out from receiving the same from RR. You accept that RR cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential Personal Data which You do not wish to communicate by email, please contact RR by telephone or post to arrange an alternative method of communication.
5.3 Telephone calls: If You call any of the service telephone numbers We provide, We may record Your call. These recordings are used for training and quality control to ensure that We continuously monitor and improve our service standards.
5.4 We may disclose your Personal Data to any Subscriber of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
7. COMPLAINTS OR QUERIES
RR tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive very seriously. We encourage You to bring any complaints to our attention by emailing email@example.com. We would also welcome any suggestions for improving our procedures. This RR Privacy Statement does not provide exhaustive detail of all aspects of RR’s collection and use of Personal Data. However, We are happy to provide any additional information or explanation needed. Any requests for this should be sent to the postal address below. If You are not happy with the way in which Your Personal Data is being handled by RR, please contact us.
8. ACCESS TO YOUR PERSONAL DATA
RR tries to be as open as it can be in terms of giving people access to their Personal Data. Individuals can find out if We hold any Personal Data by making a Subject Access Request under the Data Protection Act 1998. If We do hold Personal Data about You, We will let You have a copy of that Personal Data. To make a request to RR for any Personal Data that We may hold, You need to put the request in writing addressing it to the postal address provided below. A charge may apply.
9. HOW TO CONTACT US
Requests for information about our RR Privacy Statement or a Subject Access Request can be emailed to firstname.lastname@example.org or by writing to:
Brampton Business Centre,
10 Queen Street, Newcastle-under-Lyme,
Staffordshire. ST5 1ED
10. CHANGES TO THIS RR PRIVACY STATEMENT
We keep our RR Privacy Statement under regular review. This RR Privacy Statement was last updated in August 2016.