Privacy Policy

This privacy policy was updated in April 2021 and sets out how we use and protect any information that you give us when you use this website, our surveys, applications or work with us.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this policy.

Welbee is a trading name of School Wellbeing Accelerator Ltd, a limited company registered in England and Wales (Company number 11600110) with registered address 57 Jordan Street, Liverpool, Merseyside L1 0BW UK.

For the purposes of this privacy policy, Welbee is the ‘Data Controller’ and assumes that role under the UK Data Protection Act 2018.

We are registered with the Information Commissioner's Office, registration number ZA809755 and have appointed a nominated Officer who is responsible for all privacy related matters.

If you have any questions, please contact: hello@welbee.us

Our Contact Details

Name of Data Protection Officer: Mark Solomons
ICO Registration Number: ZA809755
E-mail address: hello@welbee.us
Address: 57 Jordan Street, Liverpool, Merseyside L1 0BW UK.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We will always endeavour to resolve any complaint or issue directly, should you contact us in the first instance.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at the above address.

We may collect the following information:

Employee information

This is where you provide us with employee information to allow us to run effective surveys and filters on your behalf. Where you provide us with this information, it is your responsibility to ensure that you have employee consent to provide this to us. The lawful basis for collecting this information is to perform a contract with you.

We may also collect information directly from employees. Where you are an employee and we do this, we may collect information regarding your job role, start date, age, employment type, department information and details of your line manager. This is in order to provide our service to you (a survey) and to allow you to participate. You do not have to provide this information, but we cannot provide the survey without it.

More specifically, we collect the following information:

Employees provide information when they complete a survey
Employers provide information about their employees such as their start date, date of birth, department or job role, whether they work part or full time, etc. They also provide their work e-mail address so we can send invitations to allow them to complete a survey.
We may also automatically collect information when a school registers to use our platform, when we administer the system on behalf of a client school, and to ensure the right access is given to users.
We also collect aggregate and summary information relating to employee engagement and wellbeing from freely available resources.

Information provided by employers and employees is used to analyse and report on surveys carried out by client schools. Information is summarised and aggregated with that of all employees and employers. It may be compared with benchmarks and with past or future data.

Information will never be used to identify individuals. All survey responses are anonymous and there is no requirement for employees to complete our surveys.

We share product information with clients and users, including new features and benefits. We ask clients to share feedback on how we might improve our products and services and may also use information to effectively manage any questions or complaints.

We do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Other information we collect:

Identity: This includes first name, surname, username, title, date of birth and gender. We use this information to allow us to provide our products or services to you, and to enable you to create an account on our site. Our lawful basis for collecting this information is to perform a contract with you.

Contact information: This includes your e-mail address, phone number, delivery address and billing address or school address. We use this information to allow us to contact you regarding your purchase of our products or services. Our lawful basis for collecting this information is to perform a contract with you.

Financial: This includes your bank account and payment card details. This is ordinarily not collected by us, as we routinely collect financial details of businesses/schools only. However, on occasion, we may collect financial details of individuals, where an individual’s payment card is used to make a purchase. Regardless, we use a third party payment processor, who will process your payment details in accordance with their privacy policy. We do not capture or store this information.

Transaction: This may include details about payments between us and other details of purchases made by you. As above, this normally relates to transactions of businesses/schools, but on occasion, there may be transactions that pertain to individuals. We collect this information in order to keep track of payments and our contractual obligations to you. Our lawful basis for doing so is our legitimate interest to ensure we are satisfying our contractual obligations with our clients.

Technical: This may include your login data, usage of our site, internet protocol (IP) addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site. This information is aggregated, and does not identify you personally. We use this information to improve our website experience. Our lawful basis for doing so is out legitimate interest to continuously improve the website we provide

Marketing and Communications: This includes your email address and preferences in receiving marketing communications, or information regarding competitions, prize draws, promotions or surveys, from us and our third parties. We will always ask for your consent before adding you to our marketing lists or providing your information to third parties to market to you. Our lawful basis for processing this information is consent. Or we will send you emails where you click links to access information from us. This is based on our legitimate interest to provide you with information we believe you have an interest in receiving.

We also make it easy to opt-out of communications by providing direct opportunities on the emails or texts we send.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions or where we have a legal obligation to retain your financial transaction data.

We may use this for

Internal record keeping.
To improve our products and services.
Contacting you from time to time for market research purposes.

Automated technologies

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

Analytics providers such as Google based outside the EU or the UK;

Advertising networks which we may utilise from time-to-time

Contact, Financial & Transaction Data from technical, payment & delivery service providers.

How we use cookies

Cookies are small pieces of information sent by a website to a visitor’s computer. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit our websites, you agree to the placement of cookies on your device. We may also place cookies from third parties for functional and marketing purposes. The use of cookies is widespread on the internet and benefits a Visitor.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over other websites.

Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this privacy statement. You should look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by clicking the unsubscribe link that we provide at the bottom of every email we send out.
Clear your cookies in your web browser and we will immediately cease to be able to directly identify your activity on our website

Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Disclosure of your personal information

We may be required to share your personal data with the parties set out below:

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Tax, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Third Party Processors

Carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

Data Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

n addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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

In some circumstances:

You can ask us to delete your data: see below for further information.

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.

We will store school data for as long as the school remains a client. In the event that your school stops using our services, we will not maintain data, unless it is anonymised, beyond a further period of 12 months.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual- rights/

If you wish to exercise any of the rights set out above, please email us at support@welbee.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Privacy Policy updates

Where we make minor changes, we will update our Privacy Policy with a new effective date.

Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.