Informed Minds Privacy Policy

What is the Informed Minds App?

Sometimes we all need a helping hand.

The Informed Minds App is a psychological well-being App that has been developed to help you feel supported and know where to get help. The Informed Minds App aims to support and help you with your Mental Health Wellbeing by providing a range of Lived and Learned short vlogs and blogs from young adults, adults and professionals on an A-Z list of Mental Health Wellbeing topics. These tools and resources are aimed at improving your wellbeing knowledge and provide a variety of practical tips that can help you maintain your personal wellbeing.

The Informed Minds App is compliant with the Data Protection Act 2018 and the EU General Data Protection Regulation (‘’GDPR’’) and UK GDPR.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Changes are not made on a retroactive basis.

This version was last updated on 12th April 2022.

It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App or the Services.

INTRODUCTION

This policy (together with our terms and conditions as set out by our Terms of Use) applies to your use of:

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. You can do so by emailing informedmindsapp@gmail.com.

This policy addresses the specific areas set out below.


IMPORTANT INFORMATION AND WHO WE ARE

Informed Minds Training & Consultancy Ltd, company number: NI663629 is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy). We have appointed a data protection officer (DPO).

If you have any questions about this privacy policy, please contact them using the details set out below.

DPO CONTACT DETAILS

Full name of legal entity: Informed Minds Training & Consultancy Ltd

Name of DPO: XpertDPO (Outsourced DPO Services)

Address: 20 Harcourt St, Saint Kevin's, Dublin, D02 H364, Republic of Ireland

Telephone: 01 678 8997

Email address: informedmindsapp@xpertdpo.com

LODGING A COMPLAINT WITH THE INFORMATION COMMISSIONER

You have the right to lodge a complaint regarding our use of your data. Please tell us first, so we have a chance to address your concerns.

You can address any complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues or to your local Supervisory Authority. For more information, please visit https://ico.org.uk/ .

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:


Special Category Data

Where we collect Special Category Data, we do so with your informed consent. You are able to withdraw this consent at any time.


Criminal Convictions and Offences

Informed Minds does not collect any information about criminal convictions and offences.

You may use the Services only if you are 16 years or older and are not barred from using the Services under applicable law. Users under the age of 18 years should have parental or guardian consent to use our Services due to the sensitive nature of some of the psychological wellbeing content. To make a purchase via the Services you must be 18 years or older and capable of forming a binding contract.

Children’s Data

You may use the Services only if you are 16 years or older and are not barred from using the Services under applicable law. Users under the age of 18 years should have parental or guardian consent to use our Services due to the sensitive nature of some of the psychological wellbeing content. To make a purchase via the Services you must be 18 years or older and capable of forming a binding contract.

This App is not intended for children, and we do not knowingly collect data relating to children. If you are aware of a user below the age of 16 using the Informed Minds App and providing personal information without parental consent, then please contact us at informedmindsapp@xpertdpo.com or use the ‘Get in Touch’ button within the Informed Minds App. · Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

HOW IS YOUR PERSONAL DATA COLLECTED?

Information you give us.

This is information you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat).

It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, or other activities commonly carried out in connection with an app and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.


Location Data

We ask you to identify your current location (country) when you download the App to connect you with the most appropriate content and services. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. Our intention is to always ensure that data minimisation principles are followed.


HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so.

We will use your personal data in the following circumstances:

Definitions for Lawful Bases are contained within the GLOSSARY.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us on informedmindsapp@gmail.com

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

User data is not intended to be shared or processed for any purpose that has not been listed above. When we collect data, we only collect what is necessary and we ensure that data minimisation principles are met by only retaining what is necessary for us to be able to provide our app and its services.

Should the purposes of data collection change, Informed Minds’ App users will be informed and consent will be re-obtained.


DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:


Informed Minds do not sell data on to third parties. However, we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

INTERNATIONAL TRANSFERS

Informed Minds application data is hosted in the European Union on AWS servers and is stored in a database that is also hosted on AWS servers based in the European Union.

Informed Minds’ application developers are based in the Republic of Ireland and Pakistan. The data shared with our developers is based on the Informed Minds application. Informed Minds utilises adequacy findings, standard contractual clauses and carries out transfer impact assessments in order to share data with third countries.

DATA SECURITY

All information you provide to us is stored on secure servers. Data on these servers is encrypted at rest and in transit (TLS: TLS v1.20) and firewalls are used to ensure security. Informed Minds’ user data is encrypted between the device and any external host storage. Penetration tests are carried out on a regular basis.

Any payment transactions carried out by us, or our chosen third-party provider of payment processing services, will be encrypted using secured encryption technology. Informed Minds does not store your payment information. The Apple and Play Stores will utilise their own secured encryption technology for In-App purchases.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so. If you have concerns about a potential data confidentiality breach, please contact us on informedmindsapp@xpertdpo.com .

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We have a Retention Policy and Retention Schedule in place, and we ensure data is destroyed confidentially when it is required to do so. Inactive user data is deleted every 12 months.

In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In some cases, by law, we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers for tax purposes.

You can delete the app at any time. If you decide to delete your Informed Minds account, your data is deleted at the same time. If you have any queries about our retention periods you can contact us on informedmindsapp@xpertdpo.com

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please see the GLOSSARY below to find out more about these rights:

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at informedmindsapp@xpertdpo.com .

GLOSSARY

1.1 LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

1.2 THIRD PARTIES

Service providers acting as processors based in the UK (Northern Ireland), Europe, and Pakistan who provide development, IT, and system administration services.

Professional advisers acting as processors, controllers or joint controllers including lawyers, bankers, auditors and insurers based in the UK and Republic of Ireland who provide consultancy, banking, legal, insurance and accounting services. HM Revenue and Customs, regulators and other authorities acting as processors, controllers or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Third parties or publicly available sources

We may receive personal data about you from our clients and various third parties and public sources as set out below:


1.3 YOUR LEGAL RIGHTS

Under the EU General Data Protection Regulation and UK GDPR, individuals have specific rights in relations to their data.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:


Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

When you are better informed you can make better life choices for yourself and help others to make better choices too.

Third party website links Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Informed Minds’ Privacy Policy no longer applies when following links to third party websites. Please check these policies before you submit any personal data to these websites or use these services.