1.1. Password and security
You are responsible for keeping your password secret and safe.
We recommend that you secure your mobile device with a secure code, meaning:
- A code of minimum 4 digits.
- To change your code at least once a year.
- To use a different code for your Howdy app, to the code you are using for your mobile device.
- Not to use zip codes, birthdates or repetition of digits.
2. Data responsibility
2.1. We take data protection seriously
We process personal data and therefore we have adopted these Terms to inform you of how your personal data is processed.
We are a data processor and we guarantee that your personal data is processed in compliance with the law.
Our contact information:
2.2. We guarantee fair and transparent data processing
When asking you to provide us with your personal data, we inform you of which of your personal data we are processing and for what purpose. You receive this information through these Terms at the time of gathering of your personal data.
3. Processing of personal data
3.1. Use of Howdy
It is voluntary for you to use Howdy.
Howdy includes one or more modules depending on the choice you make. The modules can be health related such as wellbeing scales (Howdy Wellbeing)and scales of physical pain (Howdy Body) but can also be used to gather other feedback. Some of our modules additionally include a proactive Response Team, who contacts you with the objective of advising you on how you can seek help, if you from your answers in Howdy are considered to have low wellbeing, are experiencing pain or in any other way are qualified to be contacted by the Response Team. To do this we gather different relevant information from you, for instance about your general wellbeing.
3.2. When you are using Howdy
We utilise your personal data to deliver the best services to you through Howdy, improve our service and guarantee quality.
The personal data we utilise includes:
- General personal data consisting of contact information;
- Sensitive personal data, consisting of health information about well-being, pains etc. and other health relations;
- information which is a part of requests to and from us and notes hereof.
The sensitive information we record, you have either entered into Howdy or given to our Response Team during the phone conversations, that you accept to have with the Response Team. You can always announce at the beginning of a phone conversation that you don’t wish to share your information us.
3.3. Email, text-messages and push-messages
You are automatically signed up for our “Reminder-engine” that ensures the paramount proactive action. The Reminder-engine will give you a notification when it is time to provide Howdy with your answers. Your information will not be used for marketing purposes.
3.4. We gather and store your personal data for certain purposes
Depending on which modules you have chosen, we gather and store your personal data for those purposes the modules support, for instance by monitoring your wellbeing, pain etc. and other health relations.
We gather your information from professionally relevant question frames depending on the services that you wish to utilise. This can for instance be wellbeing on the basis of the WHO-5 question frame and attempting to map your level of wellbeing on the basis of your answers. We can build on and expand these services within the purpose of Howdy.
3.5. Passing on personal data
To deliver our services to you it is necessary to be able to pass on relevant personal information about you to our Response team. The categories of recipients in the Response team include the following professional personnel:
- Psychologists, nurses or equivalent relevant professional personnel, who is staffing our well-being Response team,
- Physiotherapists (or personnel with equivalent professional insight), who is staffing our physical pain Response team,
- Other professionally competent persons to handle other professional Response teams.
The purpose of passing on your personal data is that our Response teams – on the basis of your information – can contact and advice you.
All persons staffing our different Response teams have a duty of professional secrecy and confidentiality.
3.6. The characteristics of the passed on information
All information passed on will only be passed on in anonymized form and as a part of statistical records. It is very important to us that you cannot be identified.
3.7. We only process relevant personal data
We process the personal data about you that are relevant and sufficient in terms of the purposes defined above. We do not use any other personal data than what we need for the specific purpose.
3.8. We only process necessary personal data
We gather, process and store only the personal data that is necessary in relation to meeting our set purposes.
3.9. We verify and update your personal data
We must ensure that the part of your personal data we store is correct and if needed, updated. As our service is depending on the fact that your personal data is correct and updated, we ask you to register any updates through the self-service in Howdy.
3.10. We anonymize your personal data when it is no longer necessary to us
We anonymize your personal data when it is no longer necessary in relation to the purpose of which we gathered, processed and stored it.
We anonymize all personally identifiable information immediately after you cancel your subscription with us:
3.11. We collect your consent before processing your personal data
We collect your consent before processing your personal data for the purposes described above.
You will receive a copy of your consent on email, so you can always familiarise yourself with what you have consented to. You can at any given time by sending an email to email@example.com withdraw your consent to the fact that we can process your personally identifiable information. A withdrawal of consent will imply that we can no longer deliver our services to you.
3.12. We do not pass on your personal data without your consent
By consenting to use Howdy you concurrently give us permission to pass on your information to our Response teams.
Besides that, we do not pass on your information in personally identifiable form to anyone without your consent, including use in marketing.
However, we do not collect your consent if we are legally obliged to pass on your personal data, for instance as part of a reporting to an authority.
We use the gathered information to improve our service offerings and in anonymized form for scientific and statistical purposes, where data from many users is included.
3.13. 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 well-being and calculate a well-being 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 and converts your information into causation 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.
4.1. We protect your personal data
As a data processor we have taken the necessary technical and organisational security measures against the information – obtained from you – being accidentally or illegally destroyed or are lost or altered, as well as against unauthorized disclosure, abuse or other processing in violation of the law concerning the protection of personal data. Through these two links you will find a more detailed description of our security:
Information Security Policy
Protection & Privacy
We use other data processors to store and process personal information on our account in accordance with this data policy and the current legislation. These data processors all act in accordance with the instructions they have received from us.
You can read more about our data processors here:
In case of a breach of security, resulting in a high risk of discrimination, ID-theft, economical loss, loss of reputation or other significant disadvantage for you, we will notify you about the breach of security as soon as possible.
5. Your rights
5.1. You have the right to gain access to your personal data
At any given time you have the right to be informed of which of your personal information we are processing, where it derives from and what we are using it for. You can also be informed of how long we store your personal data and who is receiving your personal data in the extent to which we are passing on personal data in Denmark and abroad.
You are entitled to data portability and thereby receive your information in a structured, commonly utilised, machine-readable format.
You can demand your rights by addressing us. Our contact information can be found at the top.
5.2. You have the right to get inaccurate personal data corrected or deleted
If you are under the impression that the personal data we process about you is inaccurate, you have the right to get them corrected. You must address us and inform us of where the inaccuracies lie and how we can correct them.
In some cases, we will be obliged to delete your personally identifiable data. For instance, this becomes relevant if you withdraw your consent. If you are under the impression that your personal data is no longer necessary in relation to the purpose they were gathered for, you can ask us to delete them. You can also contact us if you believe that your personal data is being processed in contravention with the law or other legal obligations.
When addressing us with a request to amend or delete your personal data we investigate if the conditions are fulfilled and in that case complete amendments or deletion as soon as possible.
5.3. 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. You can utilise the contact information at the top to send an objection. If your objection is legitimate we will make sure to stop all our processing of your personal data. If you wish to make a complaint about our processing of your personal data you also have the option to reach out to the Danish Data Protection Agency (Datatilsynet):
6.1. Copyright on content
All intellectual property of the content on Howdy, including the configuration, processor, design, graphics, images, etc. and any development hereof is the property of us with limitation to information on third-party sources.
The above does not entitle us to use your information on Howdy in a personally identifiable form in any other context. We solely use information in anonymized form to develop and improve the content on Howdy.
7. Limitation of liability
7.1. Limitation of liability
WLB strives that Howdy is always accessible. However, situations might occur where Howdy is not accessible, which among other things can be caused by security or maintenance reasons, network issues, failure in communication connections and hardware. We continuously create backups but cannot guarantee against the loss of data. WLB assumes no responsibility for loss or damage of content on your profile connected to such incidents.
The content of the answers you provide in Howdy can solely be used as a guide and cannot replace consultations with a doctor or other professional counsellor. If in doubt, you should always contact your own doctor. WLB do not guarantee to identify persons who are suffering from stress, depression, anxiety or other health related disorders that can affect the individual’s mental or physical well-being.
WLB cannot be held responsible for illness, death, disability or economical loss (either direct or indirect loss) on the basis of using Howdy unless this was caused by intentional or grossly negligent acts or omissions.
8. Danish law
These terms are subject to Danish law. Any dispute on the understanding of this shall be settled at the Danish Court. Previously mentioned rule on applicable law does not include Danish Law’s international legislation on private law.