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Privacy Policy

When using the services of Worklife Barometer ApS (referred to as “we”, “us” or “ours”) through the Howdy technology platform (“Howdy”), we will process your personal data.

This Privacy Policy (referred to as “Policy”) outlines how your personal data is processed.

1. Data Responsibility

We are the data controller responsible for the processing of your personal data as described in the below.

Our contact information:

Worklife Barometer ApS
Njalsgade 76,
2300 Copenhagen S
CVR: 35395539
Phone no.: +45 888 777 00
Email: gdpr@howdy.care
Website: www.howdy.care

2. Processing of Personal Data

Overview of processing activities and personal data processed.

Enrolment in Howdy until you consent

Purpose

To enrol you in Howdy and thereby deliver the services as agreed.

Personal data

  • Name (first name and surname)
  • Contact information (work email and mobile number)
  • Your birthdate
  • Your address, ZIP and city
  • Your gender
  • Payment information and history

Source

These are received directly from you.

Legal basis

(GDPR art. 6 (1)(c)). In order for us to deliver the agreed services we need your personal information.

Retention

See chapter ‎3.

Processing of your answers to questions in Howdy

Purpose

To evaluate your wellbeing and assess whether the Response Team should be activated.

Personal data

Common information:

  • Password
  • A copy of your consent to enrolling in and using Howdy
  • Preferred way of communication
  • When you last answered or partially answered a questionnaire in the module Howdy Wellbeing
  • Your answers of questions in the module Howdy Wellbeing
  • Reminders sent to you
  • Name (first name and surname)
  • Contact information (work email and mobile number)

Special categories of data in the form of health information:

  • Development of your wellbeing over time, i.e. the development in the score you receive upon answering the questions in Howdy
  • The scores relating to your wellbeing (produced using profiling based on your answers in Howdy). Whenever you provide answers in Howdy Wellbeing you will receive a score (green, yellow or red as well as a number on a scale from 0 to 100).

Source

The personal data concerning your answers and wellbeing are received directly from you when you answer the questions in Howdy.

Legal basis

(GDPR art 6(1)(c)) our obligation to deliver services to you and art 9(2)(a) your explicit consent to allow us to process special categories of personal data.

We do this by sending you questionnaires and getting you in touch, if required, with a Response Team and sending wellbeing statistics to you and using generic statistics to improve our service.

Retention

See chapter ‎3.

Interaction with the Response team

Purpose

The module Howdy Wellbeing includes a proactive Response Team that contacts you with the objective of advising you on how you can seek help, if – based on your answers in Howdy – you are considered to have low wellbeing, are experiencing pain or in any other way qualify to be contacted by the Response Team.

It is voluntary for you whether you wish to interact with and provide information to the Response Team.

Personal data

Common information:

  • Name
  • Contact information

Special categories of information in the form of health information:

  • Your answers in Howdy and dates of answering
  • Special categories of data in the form of health information (information about your mental wellbeing and developments therein as derived from or reported by you in your answers)
  • Case notes taken by the Response Team during the conversations with you, e.g., regarding any arrangements or agreements made with you regarding follow up
  • Reason codes noted by the Response Team based on the conversation with you
  • Date and time for your conversations with the Response Team as well as the name of the person you have been in contact with.

Source

The personal data is received directly from you when you answer the questions in Howdy or during your interaction with our Response Team.

Legal basis

(GDPR art 6(1)(c)) our obligation to deliver services to you and art 9(2)(a) your explicit consent to allow us to process special categories of personal data

Retention

See chapter ‎3.

Improvement and Development of Howdy

Purpose

Personal data are used to produce anonymous statistics in order to improve our service, develop new relevant services as well as ensuring that we deliver the best possible service to you, your co-workers and employees of our other customers.

Personal data

Common information:

  • Your answers to the questions in the module Howdy Wellbeing
  • Your age
  • Your gender
  • Your ZIP code and city

Special categories of information in the form of health information:

  • The scores relating to your wellbeing (produced using profiling based on your answers in Howdy)
  • Cases, case notes and reason codes

Source

The personal data concerning your answers and wellbeing and cases are received directly from you when you answer the questions in Howdy and from your interaction with a Response Team

Legal basis

GDPR art. 6 (1)(f). Our legitimate interests to improve and develop our services. Your consent to process special categories of personal data (art 9(2)(a)).

Retention

See chapter ‎3.

Security and Support

Purpose

Ensure security and monitoring activities in the platform, errors, intrusion, etc.

Managing cases for you or on your behalf.

Personal data

User behaviour including:

  • IP-addresses
  • Unique User ID
  • Initiation of and finalizing answering questions
  • Creation of case with the Response Team (date)
  • Request for log-in (date)
  • Enrolment (date)
  • Reminders sent (date)
  • System error occurred while using the system
  • Other information provided in managing a support case.

Source

Directly from you through your use of Howdy

Legal basis

(GDPR art 6(1)(c)) our obligation to deliver services to you

Retention

See chapter 3.

We utilise profiling

We utilise profiling to offer the different services in Howdy. Profiling is done by an automated run-through of your answers and awarded points. Where possible, we use an underlying professional frame of reference, such as the WHO-5 to measure wellbeing and calculate a wellbeing score.

If the profiling of your answers uncovers a need for contact, our Response Team will conduct an individual and specific evaluation of your information and will, on that basis, decide if there is a need for counselling from a health professional.

It is our Response Team who conducts a professional evaluation of the information you provide us with and converts your information into reason codes and notes that are stored in our database.

It is necessary for us to utilise profiling to be able to give you the full benefits of Howdy.

3. Data Retention

Your personal data is generally deleted when you end your subscription or withdraw your consent. We will then anonymise your answers and cases, so they cannot be traced back to you, but can be used in statistics.

Security log entries are deleted 60 days after they are created.

Support cases are delete one year after you end your subscription or withdrew your consent.

Invoicing and other bookkeeping information is kept for 5 years in accordance with applicable legislation.

4. Recipients

We do not transfer your personal data to others.

Data processors

We use data processors to store and process personal data on our behalf in accordance with this Policy and the applicable legislation. These data processors all act in accordance with the instructions they have received from us.

The Response Team is in most cases handled by personnel employed by us. However, in some cases the Response Team may be handled by one of our partners who act as data processor on our behalf and according to our instructions.

5. Transfer of personal data to third countries

Howdy is hosted on servers located within the EU/EEA and thus your personal data is generally processed within the EU/EEA.

In certain limited cases we may transfer some of your personal data to countries outside the EU/EEA (third countries). In such cases we will always ensure that appropriate safeguards are in place, e.g., by using the standard contractual clauses as adopted and published by the European Commission.

You have the right to obtain a copy of these clauses and safeguards. See chapter ‎6 on how to exercise this right.

6. Your rights

To exercise any of your rights below, reach out to us using the contact information in chapter 1. Your rights are not absolute and may have to be balanced with the rights of others as well as the rights subject to some exceptions as a matter of law.

You have the right to gain access to your personal data

At any given time, you have the right to access your personal data. This means that you can request:

  • Our reasons for processing
  • The categories of the processed personal data
  • Recipients or categories of recipients to whom we transfer your personal data
  • The period of time that we keep your personal data
  • The source of the personal data
  • Whether we profile the personal data
  • Contractual clauses or guarantees for our transfer of personal data to third countries.
  • A copy of your personal data

You may have the right to data portability

You may be entitled to data portability and thereby receive your information in a structured, commonly utilised, machine-readable format. This only applies where all of the following criteria are met: i) the legal basis for our processing is your consent or our contract with you, ii) the processing is carried out by automated means, and iii) the information has been provided by you about yourself.

You have the right to get inaccurate personal data corrected

If you are under the impression that the personal data we process about you is inaccurate or incomplete, you have the right to have them corrected.

You have the right to request deletion of your personal data

When you do not want us to process your personal data any more, you have the right to ask us to delete your personal data.

You have the right to object to our processing of your personal data

You have the right to object to our processing of your personal data. This right only applies insofar as the legal basis for the processing is based on our legitimate interests or public interest. If we cannot demonstrate compelling legitimate grounds for continuing the processing, we will make sure to stop the relevant processing of your personal data.

You have the right to request that the processing of your personal data is restricted

Under certain circumstances you have the right to have the processing of your personal data restricted.

You have the right to withdraw your consent

Where the processing of your personal data is based on your consent you have the right to withdraw your consent at any given time. You can do that in the app or by sending an email to opt-out@howdy.care. A withdrawal of consent will imply that we can no longer deliver our services to you. However, the withdrawal does not affect the legality of the processing of your personal data that took place prior to the withdrawal.

You have the right to complain to a supervisory authority

If you wish to make a complaint about our processing of your personal data, you also have the right to reach out to a supervisory authority. Below you will find contact information for the Danish Data Protection Agency (Datatilsynet):

Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Phone no.: +45 33193200
Email: dt@datatilsynet.dk
Website: www.datatilsynet.dk

7. Amendments to this privacy policy

This Policy is reviewed on a continuous basis to make sure it is up to date. Thus, we reserve the right at any given time to amend this Policy and in case any material amendments are made we will inform you in the app. The applicable Policy is accessible on Howdy at any given time.

This Policy version 3 was last amended in February 2021 and replaces any previous versions.

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