We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website and use our Wellbeing Check-In platform (regardless of where you visit it from). We'll also tell you about your privacy rights and how the data protection law protects you.

1. Who we are and important information

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website and our Wellbeing Check-In platform, including any data you may provide through this website, the platform, our questionnaires or when you request information or buy our service (or a trial thereof). You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that youare fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

Feedback 360 Limited is the controller and responsible for your personal data (collectively referred to as FB360, "we", "us" or "our" in this privacy notice). Our contact details are 124 City Road, London, EC1 2NX. For all data matters contact dpo@govox.com.

Where we are acting under a contract with your organisation we act as a data processor - if you are interested in the purposes and lawful basis of processing your organisation relies on when it processes your personal data please contact them.

2. The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified and which relates to them. You can find out more about personal data from the Information Commissioners Office. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name and gender.

• Contact Data includes email address and phone number.

• Organisation Data includes organisation you are at, your role title, and department/team/class and other custom fields requested by your organisation.

• Technical Data includes 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 this website.

• Usage Data includes information about how you use our website, products and services.

• Profile Data includes your username and password, country, language settings and questionnaire responses (which constitute special category data).

We also collect and use aggregated data. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect your personal data by law, or under 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How we collect your personal data

We use different methods to collect data from and about you including through:

• Receiving your Identity Data, Contact Data and Organisation Data from the organisation you are part of when they sign up to Govox.

• Direct interactions with you. You may give us Profile Data when you use the Wellbeing Check-In platform or when responding to the questionnaires.

• Automated technologies or interactions. As you interact with our website or the Wellbeing Check-In platform and questionnaires, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract this means processing your data where it is necessary for the performance of a contract.

• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you and your employer the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so where we act as a data controller.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us on dpo@govox.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please see our cookie policy for further details.

Change of purpose

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we mayprocess your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Who we share your personal data with

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties including

• Service providers acting as processors who provide IT and system administration services.

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

• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

• 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: sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

• If you are participating in a Wellbeing Audit facilitated by Govox, please be aware that the results of your audit may be shared with the partner organisation that is conducting the audit in collaboration with us. This sharing of information is crucial for the partner organisation to provide tailored advice, services, and support based on the audit outcomes.

7. International transfers

If your organisation is based wholly or partially outside of the UK, processing of your personal data may involve a transfer of personal data outside of the UK. Separately some of our external third parties are based outside the UK so their processing of your personal data by them will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that it is either to a country that have been deemed to provide an adequate level of protection for personal data; or if not then we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data security

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

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances 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.

10. Your legal rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you; The right to request that we correct any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary to retain such data;

• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer (dpo@govox.com)

No fee required - with some exceptions

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 ad min fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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 askyou for further information in relation to your request to speed up our response.

Time limit to respond

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.

11. ICO

We are committed to ensuring the protection and privacy of the personal information we process. In alignment with this commitment, Feedback 360 is registered with the Information Commissioner's Office (ICO) under registration number ZA554249, adhering to the Data Protection Act 2018 and the UK GDPR. This registration reflects our dedication to comply with the applicable data protection laws and regulations, safeguarding the personal information under our care.

For further details about our registration and our data protection practices, please contact our Data Protection Officer at dpo@govox.com

12. Changes to this notice and your duty to inform us of changes

This version was last updated on 18th Match 2024.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

13 Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer (dpo@govox.com)

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.