Paradym Limited respects your privacy and is committed to protecting your Personal Data. We want to
be transparent with you about how we collect and use your Personal Data in making available the website, www.theparadym.com (the “Site”), the Paradym mobile application (the “Application”), and the “Guided Process Programme”, which refers to our coach-led wellness programme, and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us.
- Your rights relating to your Personal Data.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use your Personal Data and why.
- What happens when you do not provide necessary Personal Data.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Third party links.
Who we are and how to contact us.
Who we are.
Our address is: 4 Endsleigh Street, London, WC1H 0DS, United Kingdom.
How to contact us.
You can contact us by emailing: firstname.lastname@example.org.
Our Data Protection Officer.
Your rights relating to your Personal Data.
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your
particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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 relates 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to
provide you with access to the certain specific functionalities of our Site and/or Application and/or the Guided Process Programme. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, 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.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, youalso have the right to contact the Information Commissioner’s Office, the UK regulator for data protection issues. If you are based in the European Union (EU), you may contact your local supervisory authority (see here).
Marketing communications preferences.
You can ask us to stop sending you marketing messages at any time by logging into the Application and checking or unchecking relevant boxes to adjust your marketing preferences.
Please note that where you opt out of receiving marketing messages we will still contact you regarding, and process Personal Data in connection with, non-marketing matters, such as purchases, subscription renewals, announcements and updates regarding the Site and/or Application and/or the Guided Process Programme, security alerts and support.
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The UK GDPR definition of Personal Data can be found here. Essentially, it means: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of an individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible
information, could be attributed to a particular person).
Category of Personal Data collected
What this means
|Identity Data||First name, surname, username or similar identifier, title and date of birth.|
|Contact Data||Your email address. Apple, our platform provider, may also collect your home address, billing address and telephone number.|
|Financial Data||Apple, our platform provider, may collect your bank account and payment card details, on our behalf.|
|Transaction Data||Details about payments to and from you and other details of subscriptions and services you have purchased from us. Apple, our platform provider, may collect data in respect of your transactions with third parties (including your credit history).|
|Marketing Data||Your preferences in receiving marketing from us.|
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for men, living in London and aged under 25, who like sports).|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site or Application or use our services.|
|Mental Health Data||Your goals and aspirations before starting the Guided Process Programme, information about the status of your mental health that you may share with us through the Application or otherwise during the course of the Guided Process Programme: wellbeing, life satisfaction, depression, emotional awareness, and anxiety.|
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will
Special Categories of Personal Data
The UK GDPR defines “Special Category Data” as Personal Data relating to one’s: (i) racial or ethnic origin, (ii) political opinions, (iii) religious or philosophical beliefs, (iv) trade union membership, (v) genetic data, (vi) biometric data, (vii) health, (viii) sex life, or (ix) sexual orientation. We do not ask you for, or intend to collect, any “Special Categories of Personal Data” about you other than to the extent that the Mental Health Data referred to above amounts to information about your health. .
Where we do collect and process Mental Health Data about you, we only do so on the basis of your prior explicit consent and for the specified purpose(s).
We do not collect any information about criminal convictions and offences. We ask that you do not voluntarily provide any information about criminal convictions and offences to us.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
We want to provide you with the most helpful service we can. In respect of each of the purposes for which we use your Personal Data, the UK GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract (i.e., a subscription) we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not
override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your Personal Data.
Category(ies) of Personal Data involved
Why do we do this
Our legal basis for this use of data
||To register you as a new customer.||Contractual Necessity|
|To process payments for subscriptions to the Site and/or Application (and their associated services and functionalities, including the Guided Process Programme)||
||To process and deliver your order including manage payments, fees and charges.||Contractual Necessity.|
||To keep the Site and/or Application, our services and associated systems operational and secure.||Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our services, Site and associated IT services and networks.|
|Troubleshooting||Technical Data||To track issues that might be occurring on our systems.||Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Site and/or Application and associated systems and services.|
||To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||Legitimate Interests. We have a legitimate interest in providing you with updates on our Site and/or Application and related offers where you have purchased or shown interest in similar services from us.|
|Operation of the Guided Process Programme||
What happens when you do not provide necessary Personal Data?Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site and/or Application and/or the Guided Process Programme). In this case, we may have to stop you using our Site and/or Application and/or the Guided Process Programme but we will notify you if this is the case at the time.
Personal Data from Third Party SourcesIn addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
Third party data source
Category(ies) or other types of personal data received.
|Social Media Sites||Yes||
What are cookies?We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Site.
Cookies we useOur Site uses the following types of cookies for the purposes set out below:
Type of cookie
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookie s] You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
Disabling cookiesYou can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk. You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB] We may also use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”)) on our Site to collect and store information about your use of our Site. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings.
Blocking Flash CookiesIf you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Site.
Pixel TagsWe may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively.
Mobile Advertising IdentifiersWe may collect, and may associate information with, mobile advertising IDs (such as iOS Advertising Identifiers and Google’s Advertising IDs) on the Sites. These are unique identifiers (which are resettable) set by the Sitelicable mobile operating system provider (“Mobile Advertising IDs”).
How to opt-out of / reset Mobile Advertising IDs iOS:
- Go to ’Settings’
- Scroll down to ‘Privacy’
- Scroll down to ‘Advertising’
- Shift the ‘Limit Ad Tracking’ slider to the right.
- Go to ‘Settings’
- Scroll down and click on ‘Google’
- Scroll down and click on ‘Ads’
- Shift the ‘Opt out of Ads Personalisation’ slider to the right.
Do Not Track SignalsSome Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
No Cross Device TrackingAlthough we collect information via the various “tracking technologies” referred to above – we do not engage in ‘cross-device tracking’. This means that we do not link information collected via multiple identifiers across your different devices and browsers to create a consolidated picture of your cross-device online activity or behaviour.
Who we share your Personal Data with.The table below describes who we share your Personal Data with, what we share and why we share it.
Category(ies) of Personal Data we share.
Why we share it
||Our service providers provide us with IT and system administration services.||Worldwide|
||Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.||Worldwide|
|Trained therapists involved in the Guided Process Programme||
||The coaches and therapists running the Zoom group sessions as part of the Guided Process Programme will need to have information about the participants.||UK|
|HM Revenue & Customs, regulators and other authorities||
||Authorities may require reporting of processing activities in certain circumstances||Worldwide|
Data transfersAs you can see from the above, we share your Personal Data with certain external third parties who are based outside the UK We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
How we keep your Personal Data secure.We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above see section on “How we use your Personal Data and why.” Unless a longer retention period is required by law (for example for regulatory purposes). The table below shows our standard retention practices:
Category of Personal Data
|Behavioural Data Marketing Data||For so long as you remain a customer of ours.|
|Identity Data Contact Data Financial Data Transactional Data Mental Health Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see “How we use your Personal Data and why.”). For so long as you are participating in the Guided Process Programme.|