Company Number 12347173
27 Drayton Gardens, London, N21 2NR, United Kingdom
- Business contacts
- Employees/Staff Members
1.2. Processing Data on Behalf of a Controller and Processors’ responsibility to you. In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
- Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
- Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
- Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority; and
- Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain their expert knowledge.
2. LEGAL BASIS FOR DATA COLLECTION
- Profile/Identity Data: This is data relating to your first name, last name, gender and date of birth.
- Contact Data: This is data relating to your phone number, addresses, email addresses and phone numbers.
- Political Data: Information about race, or ethnicity, religious beliefs, sexual orientation and political opinions
- Health Data: Information about health, including any medical condition, health and sickness records. In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.
2.2. The Legal Basis for Collecting That Data. There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
- “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards. For the special categories of data that we collect, the enhanced legal justification we rely on is:
3. HOW WE USE YOUR PERSONAL DATA
3.1. Our Uses. We will only use your Personal Data when the law allows us to. Section 2.1. explains the different types of Personal Data we collect and section 2.2. the lawful basis for processing that data. Examples provided in section 2.1. are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.
3.2. Marketing and Content Updates. You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3. Change of Purpose. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer. 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 may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1. How Does MyMynd Limited Protect Customers’ Personal Data? We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including We implement certain security measures to ensure the security of your Personal Data on our systems, including end to end encryption and encrypting our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of MyMynd Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.2. Opting Out Of Marketing Promotions. You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.3. How to Request your Data and the Process for Obtaining it. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request. We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
5. YOUR DATA AND THIRD PARTIES
HOW LONG WILL WE RETAIN YOUR DATA FOR? We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
AGE LIMIT FOR OUR USERS. You must not use MyMynd Limited unless you are aged 16 or older. If you are under 16 and you access MyMynd Limited by lying about your age, you must immediately stop using MyMynd Limited. This website is not intended for children and we do not knowingly collect data relating to children.
INTERNATIONAL TRANSFER OF DATA. Your information may be stored and processed in the US or other countries or jurisdictions outside the US where MyMynd Limited has facilities. We are currently storing data in the EU and so, by using MyMynd Limited, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
INTERPRETATION. All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.). Our staff are not authorised to contract on behalf of MyMynd Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a MyMynd Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any MyMynd Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the MyMynd Limited legal department.