Effective Date: 13 December 2018, revised on 25 February 2019
SCOPE OF POLICY
Definitions used in this policy are the same as those used in our user terms.
INFORMATION WE COLLECT
We collect and process the following data (information) when you provide it through the use of our service:
Information you give us: Clients, Admins and End-users (you), may give us information about you when downloading, registering to use the App or using the App. When using the App you will give us information for example via your input in the different features of the App (your mood, survey, polls, e.g.). You will also send information when corresponding with us (for example by email) and when reporting a problem with the App. Information may include your name, email address, phone number, age, username, password, other registration information, personal description, photograph, job title and employer.
Information about you contained within the content you send and receive on the App: CHO, each employees’ own personal Chief Happiness Officer, is a human-centric, easy-to-use mobile application, designed to foster the Voice of Employee and create a superior Employee Experience (EX) to increase employee engagement. It is inevitable, therefore, that messages you send or receive or content you share on the App may contain personal information about you and other people. We take extra care to store this information securely and in a way that protects your privacy.
Information provided when you connect The App to your Third Party services: We receive information about you when you or your administrator link to a third-party service with our Services. If you or the client authorizes CHO to connect to a platform of a third party, we receive a token that allows us to access your data of that specific platform, limited to the scope of permissions you or the client grants. Depending of the third party and the agreements with the client it is also possible that we mass import the data from this service or the other way around.
Information we automatically collect each time you use the App: When you use the app we collect some information to help us improve our services:
- Device and session information: technical information, including the type of Device you use, a unique Device identifier (for example, your Device's token or your specific Device number), your IP address, time zone setting, etc;
- Metrics on use of the app: details of your use of any of the features of the App including which features your use from the app, how many times you open the app, when you connect 3rd parties services and other key events.
HOW WE USE INFORMATION
We use the Information you give us and that we collect in the following ways:
- to make the App and the services it provides available to you;
- to personalize the service to your needs;
- to allow you to participate in interactive features of the App, when you choose to do so;
- to send you service and administrative in App communications and notifications such as those reminding you that you have an open action;
- to allow you to connect to, or link through to non-CHO Services;
- to provide you with support;
- to ensure that the App is presented in the most effective manner for you and for your Device;
- to notify you about changes to the App;
- to provide you with information about other apps and services we might offer that are similar to those you have already use;
We may use the Information we collect from your Device:
- to administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the App;
- as part of our efforts to keep the App safe and secure.
A note on the information about you contained within the content you send and receive on the App: The information that you send and receive in the App for diverse purposes is anonymously disclosed to a Management Dashboard. This Dashboard is accessible for the client and the appointed managers. There is no possibility that the information shown on the Dashboard can be related to a specific user. On the Dashboard there is no overview of which users added which data, only anonymous data is visible that is aggregated to team/department level.
Besides the information that is mentioned above, we may occasionally be required to disclose such Information as set out below.
INFORMATION WE SHARE/DISCLOSE
We may share your Information as follows (on occasion this may include Information about you contained within the content you send and receive on the App, but this will only be when absolutely necessary):
- with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
- in the event that we sell or buy any business or assets, in which case we may disclose your Information to the prospective seller or buyer of such business or assets;
- if CHO or substantially all of our assets are acquired by a third party, in which case Information held by us about our customers will be one of the transferred assets;
- if we are under a legal duty to disclose or share your Information in order to comply with any legal or regulatory obligation or request;
- in order to enforce or to investigate potential breaches of the Terms or to protect the rights, property or safety of CHO, our customers, or others.
We may share anonymous End-users Information with the relevant Client and/or Admin.
We may share disaggregated/anonymised information with selected third parties as appropriate and with analytics and service providers that assist us in fault diagnostics, the improvement or the optimization of the App.
Unfortunately, the transmission of any information via the internet is not completely secure. We will do our best to protect your Information through the use of appropriate technical measures such as encryption, but we cannot guarantee the security of Information transmitted; any transmission is at your own risk.
Information in transit between our servers and you over the internet is encrypted using industry wide accepted standards.
Once we have received your Information, we use strict procedures and security features to try to prevent unauthorised access. All Information we hold is stored on secure servers.
OUR LEGITIMATE INTERESTS
For our European Economic Area (EEA) users, we process your information in furtherance of our legitimate interests, including:
providing the Services, including any personalised Services. We do so as it is necessary to pursue our legitimate interests of providing the CHO service in a way that meets the needs and expectations of our users; and
improving the Services, including any personalised Services. We do so as it is necessary to pursue our legitimate interests of developing innovative and tailored offerings to our users on a continually improving basis; and
keeping the Services safe and secure. We do so as it is necessary to pursue the legitimate interests of CHO and its members in ensuring the Services are secure, and to protect against fraud, spam and abuse, etc.
WHERE WE STORE YOUR PERSONAL DATA
It could be possible that when we work with a third party they are transferring your data outside of the European Economic Area (EEA). If this is the case we have taken reasonable steps to ensure the third party is GDPR compliant.
HOW LONG WE STORE YOUR DATA FOR
We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted, whichever comes first.
Where you withdraw your consent to CHO processing your data, we will delete all information you provided. Following the deletion of your account, it may take up to 30 days to fully delete all personal information from our systems. Note that the content you have shared with CHO will remain anonymous visible on the Management Dashboard after your account has been deleted.
Information about you that is no longer necessary and relevant to provide our Services may be anonymised, and aggregated with other non-personal data, to provide insights which could be commercially valuable to CHO, such as statistics of the use of the Services. For example, we may retain anonymised data on how people use or interact with the app.
If you register or access the Services using an email address within a domain that is owned by your employer or organisation, or if you associate that email address with your existing organisation account and such organisation wishes to establish a CHO organisation account, certain information about you including your name, profile picture, contact info will become under the control to that organisation’s administrator.
In the case that the Services are made available to you through an organisation (e.g. your employer), we retain your information as long as required by the administrator of your account. This does not impact your personal rights, but if you choose to exercise certain rights listed below it may result in you being unable to continue using the service as provided via your organisation.
You have the right to ask for copies of all the information we hold on you: This report will include the Personal Data we have about you, provided to you in a structured, commonly used and portable format. Please note that CHO may request additional information from you to verify your identity before we disclose any information. If you wish to request a copy of your data, please contact us via Contact.Ex@atos.net so we can assist you.
You have the right to have your personal data corrected: You can correct or change your personal data within the Settings and Profile areas of the app. If you need assistance or find you can't edit the data you'd like to change, please contact us via Contact.Ex@atos.net.
You have the right to have your personal data deleted: You may request that your account is deleted by contacting us via Contact.Ex@atos.net. Once deleted, your data, (including your account) cannot be accessed. Note that the content you have shared with CHO will remain anonymous visible on the Management Dashboard after your account has been deleted.
You have the right to object to us processing your personal data: You can ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing emails. You may withdraw your consent at any time by clicking the “Unsubscribe” link found within CHO emails. Please note you will continue to receive transactional messages related to our Services, even if you unsubscribe from marketing emails.
We will also send you messages and emails that are of a service or administrative nature, but you may not opt out of these while you have an active account.
The App may contain links to and from non-CHO Services. Please note these non-CHO Services may have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these non-CHO Services, such as contact and location data. Please check these policies before you submit any personal data to these non-CHO Services.
We use the following types of cookies:
- Strictly necessary cookies: These are cookies that are required for the operation of the App via your browser. They include cookies that enable you to log into the App or make use of e-billing services.
- Analytical/performance cookies: These help us to improve the way the App works; (for example, by ensuring that End-users can find what they are looking for easily).
- Functionality cookies: These are used to recognise you when you return to the App. This enables us to greet you by name and remember your preferences; (for example, your choice of language or region).
You may block cookies by activating the setting on your browser that allows you to refuse all or some cookies. However, if you do you may not be able to access all or parts of the App via your browser.