Policies

Privacy Policy

Website GDPR and privacy policy

This Privacy Policy, which has been updated to include the requirements of the General Data Protection Regulation (GDPR describes how your personal information is collected, used, and shared when you visit or make a purchase from www.moodbeam.co.uk (the “Site”).

SECTION 1 - PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, email address, and phone number where necessary. We refer to this information as “Order Information”.  Payment information including credit card number information is stored by our payment gateway providers Stripe and PayPal.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

SECTION 2 - HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). We use Stripe and PayPal for payment processing which means that no payment details are stored on our server. PayPal is a payment solution for businesses, which allows us to accept payments by PayPal as well as credit cards and debit cards (“Cards”). Similarly, Stripe allows us to integrate an alternative payment option to accept all major credit cards.

Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

You can opt out of targeted advertising by:
FACEBOOK -https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous
BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

SECTION 3 - DOES MOODBEAM SHARE THIS INFORMATION WITH OTHERS?

Moodbeam will never sell any personal data you submit to us to a third party.

Non-personal information may occasionally be used to compile statistics that may be shared with others – e.g. the number of visitors to the site, etc.

Some areas of the site, such as the email newsletter or sections involving online payment, depend on applications or software built by trustworthy, reputable third parties. These third parties are bound by similar privacy and data protection requirements as Moodbeam. For more information, see the Moodbeam.co.uk terms of use

Personal data will only be released to external sources in order to comply with applicable laws, summonses, search warrants, court or regulatory orders, or other statutory requirements.

SECTION 4 - DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

SECTION 5 - YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

SECTION 6 - DATA RETENTION

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

SECTION 7 - CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

SECTION 8 - SECURITY

Personal data submitted to Moodbeam.co.uk is held on secure servers. While no data transmission over the internet can ever be guaranteed to be 100% secure, we will take all reasonable steps (technically and organisationally) to protect your information. We will also work only with third parties with clear and suitable privacy and data protection policies of their own. See the Terms of Service for more information on these third parties. Where you are directed to a third party site, please read their terms of service before submitting your details.

SECTION 9 - CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@moodbeam.co.uk or by mail using the details provided below:

Moodbeam, 31-33 Queen's Street , Hull, HU1 1UU, United Kingdom

App Privacy Policy

This notice tells you what to expect when Moodbeam Ltd uses your personal data.

It does not provide exhaustive detail of all aspects of our collection and use of personal data, but we are happy to provide any additional information or explanation needed.

Any requests for this should be sent to mydata@moodbeam.co.uk.

This privacy notice applies to information we collect about:
• Users of our application and connected devices;
• People with whom our users choose to share data collected by our device and application.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 6th November 2019.

Who is Moodbeam Ltd?

Moodbeam Ltd (Moodbeam) is a limited company registered in England & Wales No 10349738 and our registered address is: Centre For Digital Innovation, C4di At The Dock, 31-38 Queen Street, Hull, England, HU1 1UU, UK.

Moodbeam is committed to protecting and respecting your privacy and our use of personal data is aimed at helping us achieve these aims and to provide our users with the best, most insightful application experience we can.

Contacting Us

If you have any questions or concerns about our personal data policies or practices, please contact us at the address above or:
email: mydata@moodbeam.co.uk

Moodbeam as a Data Controller

When using your personal data, Moodbeam is a "Data Controller". This means that we are responsible for deciding how we hold and use your personal data.

You may also authorise us to share your information with other organisations e.g. with your employer when you choose to participate in an employee assistance program or with a healthcare provider as part of your treatment under them.

In these cases, those organisations are Data Controllers in their own right and their use of your information will be governed by their privacy policies.

If you are not sure, you have the right to ask us – at any time – who we may be sharing your personal data with. You can also revoke your consent to share with other Data Controllers by contacting us at mydata@moodbeam.co.uk.

Your Rights

The European Union’s General Data Protection Regulation provides you with certain rights. A good explanation of them (in English) is available on the website of our national privacy regulator, the Information Commissioner’s Office.

In the UK you have rights as an individual under the Data Protection Act 2018 which you can exercise in relation to the information we hold about you.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

A right to information and access

You have the right to know whether Moodbeam is processing your personal data and to have access to the personal data we may have about you.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who we might have shared the data with; what the source of the information was (if you didn’t provide it directly to us); and how long it will be stored for.

Reasonable access to your personal data will be provided at no cost upon request made to mydata@moodbeam.co.uk.To make sure we do not disclose your information to someone else, we may ask you to provide information to confirm your identity. This may include asking you to provide identification documents.

If access cannot be provided within 30 days, we will provide you with a date when the information will be provided.

If for some reason access is denied, we will provide an explanation as to why access has been denied.

A right to correct

You have a right to correct the information we hold about you if it is inaccurate. Where we need to investigate the accuracy of the data, you have the right to request we restrict our use of that data.

A right to erasure

You may request that we erase the data we hold about you; but this is not an absolute right and is subject to exceptions. Where we have a lawful reason to retain your data even when you request we delete it, you have the right to restrict our use of your data to that reason only.

You can delete your account by:
• contacting us by email to mydata@moodbeam.co.uk

If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information e.g. the data stored in our backup systems.

If you have taken steps to share your data with other Moodbeam users, you also have the option to remove access to the information other users hold about you on their app by removing their name from your shared contacts list. Once you have removed a user from your shared contacts list that user will no longer be able to see or access any Moodbeam data linked to your profile.

Be mindful that if you only delete our application from your device without submitting a request for your personal data to be deleted, your account and associated information will still be stored in our servers.

A right to not be subject to automated decision making

You have the right to object to a decision which has been made solely by automated reasons. Essentially, this right allows you to request that the decision is reviewed by a human. We do not carry out any automated decision making but please contact us if you require any more information on how this right may apply to you.

A right to data portability

When technically feasible, we will—at your request—provide your personal data to you or transmit it directly to another controller in a commonly used, machine readable format e.g. csv.

A right to complain

You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we use your personal data. In the UK this is the Information Commissioner’s Office – www.ico.org.uk/concerns.

The reasons we can lawfully use your data

We only use your personal data when we have a lawful basis to do so.

Data Protection legislation sets out a number of these, but the ones we most commonly use are:

Consent

In most situations, we collect and use your personal data with your consent e.g. when you use button presses to record how you feel or when you ask us to share your information with another user.

Performance of a Contract

In some cases, we need to use your personal data in order to provide the goods and services you have asked us for (or to allow others to do so on our behalf) .i.e. to provide you with the ability to track your mood, record journal events and make that information available to the people you choose to share it with.

Legal Obligation

If the law requires us to, we may need to collect and process your data.

Legitimate interest

We may use your personal data to pursue our legitimate businesses interests in a way which might reasonably be expected as part of running our business as long as it does not materially impact your interests, rights and freedoms.

These legitimate business interests can include:
• enhancing, modifying, personalising or otherwise improving our application and related communications for the benefit of our users;
• understanding how people interact with and use our application.

This can also apply to uses which are in your interests and those of others such as those which
• identify and prevent fraud or other illegal activity;
• enhance the security of our network and information systems.

You have the right to object to our processing of your personal data for our Legitimate Interests at any time. Please contact us if you have any further questions about our use of your data in our legitimate interests.

Where is your data stored?

Moodbeam uses Amazon AWS and Google Cloud services to securely store and manage personal and MOODDATA for our users. You can find out more about the services provided by Amazon AWS and Google Cloud via their own websites. To find out more about Amazon AWS please visit their knowledge base (https://aws.amazon.com/premiumsupport/knowledge-center). To find out more about Google Cloud services please visit their website (https://cloud.google.com/security/).

When do we collect your personal data?

• When you create an account;
• When you register a device to that account;
• When you use the device to record your MOODDATA;
• When you add journal or other information to your account using the app;
• When someone chooses to share their MOODDATA with you.

What personal data do we collect?

The amount of information we collect about you depends to a great extent on how you use your Moodbeam device and make use of additional functionality within the app e.g. by recording journal notes next to your MOODDATA entries.

The table below sets out the main categories of personal data we collect although this may not be an exhaustive list.

Profile Data
• Your name and email address.
• Date of birth.
• Gender (you are able to select ‘Rather Not Say’).
• Username and password

Device & Usage Data
• includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• includes details of your use of any of our Apps or your visits to any of our sites including, but not limited to, traffic data and other communication data and the resources that you access.

Behavioural Data
Depending on how you use the Moodbeam device and application, we may gather information about your habits and activities.
This is information you log in your journal which may include details of your activities and other life events.

Special Categories Data
While not medical data, the information you provide about how you feel provides insight into your mental health and could be used in conjunction with a professional as an informal record to aid any counselling or other treatment you are receiving.

This includes aspects of the information about your sleep and activity patterns which are collected by the Moodbeam device while you are wearing it.

It also includes some types of information you log in your journal which may include details of your lifestyle, information about smoking and drinking habits, medication.

This information is collected when you choose to provide it – by using a button press to indicate how you feel or making a journal entry.

Location Data
When using the Moodbeam App on an Android device to connect to a Moodbeam wearable device it is important to understand that to allow the App to initiate and maintain this Bluetooth connection, Moodbeam is required to collect location data even when the app is running in the background or not in use. Disabling locational data sharing can be done through your device settings, however in doing so the Moodbeam App will no longer be able to initiate or maintain a Bluetooth connection between the Moodbeam App and your Moodbeam wearable device.

We keep our privacy notice under regular review. This privacy notice was last updated on 6th November 2019.

How do we use it and why?

Purpose
• To install the app and register you as a new App user.
• To manage our relationship with you including notifying you of changes to the App or any Services including downtime and update information and to give you customer support.

Data categories
• Profile Data
• Device and Usage Data

Lawful basis
Performance of our contract with you.

Purpose
• To take reasonable steps to identify those users for who we may need additional sign up steps or protective measures as required by law e.g. to identify users under the age of 13 for whom we need to obtain parental consent.

Data categories
• Profile Data
• Device and Usage Data
• Behavioural Data

Lawful basis
Compliance with a Legal Obligation.

Purpose
• To provide you with access to a log and a visual representation of the factors which affect how you feel.
• To enable you to share the information you have recorded with the people and organisations you choose to.

Data categories
• Behavioural Data
• Special Categories Data

Lawful basis
Consent

Purpose
• To administer our business and this App including troubleshooting, data analysis and system testing.
• To monitor trends so we can improve and personalise our app and services.
• To protect our business and your account from fraud and other illegal activities e.g. to authenticate users.
• To identify groups of users who may benefit from purpose-built functionality or information e.g. by providing links to relevant wellness resources to users of a certain gender and age group.

Data categories
• Profile Data
• Device and Usage Data

Lawful basis
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

The data of children

The Moodbeam story began with our founder needing a way to help her daughter deal with a tough situation at school and log how she felt so they could talk about it when their day allowed.

Unless the app and device are being used in the context of preventive or counselling services offered directly to a child, parents or guardians must consent to the use of the personal data of a child under the age of 13.

If we learn we have collected the personal information of a child under the age of 13 without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at mydata@moodbeam.co.uk.

Using your data for research and measurement purposes

We want to give you the best possible experience and provide you with real insight into how you feel.

One way to achieve that is to get the richest picture we can of our users as a whole and by groups.

We then use this picture to offer you additional insights such as how you compare with our users as a whole or with others like you based on indicators such as your age range or gender.

We also combine this with external information such as news events or weather patterns to provide insight into how these affect the mood of our users as a whole.

e.g. We may use aggregated information about our users to provide insight into how the Christmas holidays affected the general mood of our users.

When we use your information in this way, we only do so in a de-identified, consolidated format in which information identifying you as an individual has been removed. We only conduct analysis and research on this separate dataset and never on your individual account.

How we protect your personal data

We keep our privacy notice under regular review. This privacy notice was last updated on 6th November 2019.

How long will we keep your personal data?

We keep our privacy notice under regular review. This privacy notice was last updated on 6th November 2019.

Who do we share your personal data with?

We do not reveal your personal data to third-parties unless:
• you request or authorise it e.g. if you use the app to share your MOODDATA with your family members or friends; or
• the information is provided to comply with the law (for example, to comply with a court order); or
• to protect our rights, property or safety, or the rights, property or safety of our employees or others. This includes exchanging information with law enforcement organisations for the purposes of the detection or prevention of crime; or
• the information is provided to protect your health, safety or other vital interests or the health, safety or other vital interests of another; or
• the information is provided to our sub-contractors, agents, vendors or service providers who perform functions on our behalf; or
• to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

Examples of the kind of third parties we work with

IT, software and SaaS companies who support our application and other business systems.

These include Amazon Web Services and Google who provide the infrastructure on which our application is built.

These companies are data processors for Moodbeam Ltd which means they only use your data in order to provide the technical services we ask them to.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

We may, from time to time, expand, reduce or sell Moodbeam Ltd and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

Where your personal data may be processed: As part of our commitment to your Privacy, we usually opt to have your data stored in the UK or EU where possible.

Our application servers are all in data centres located in the EU and our application does not transfer your data outside the EU for any reason.