Welcome to the Mind Strength for Business’s privacy notice and thank you for choosing to take part in one or more of our suite of online and real time mental wellbeing programmes (Programme).

The Programme operates from our unique platform, called HeadForwards On-Demand Platform, which is hosted for us at https://ondemand.head-forwards.com/login by Mole Productions Limited. You will have been sent details of how to access our HeadForwards On-Demand Platform together with a unique user profile and password to access our HeadForwards On-Demand Platform. You will also need a mobile phone to be able to access the HeadForwards On-Demand Platform as your secure area is protected by two-way authentication.

You must be at least 18 years of age to participate in our Programme.

Before you can start the Programme:

• We need to tell you what will happen to the information you have given to us already and/or to information you upload to your protected area of our HeadForwards On-Demand Platform.
• We also need to obtain your explicit consent to how your information is processed by us because it is sensitive to you.

If we do not have your explicit consent, then you will not be able to access this Programme and your access to our HeadForwards On-Demand Platform will cease.

It is important therefore that you read this privacy notice which contains detailed information about how we process your information and to provide your consent at the end of this notice.

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE GIVING YOUR CONSENT. YOU WILL NEED TO CONFIRM YOUR CONSENT AT THE BOTTOM OF THIS POLICY.

1. Who we are and how to contact us

mindstrengthforbusiness.com limited is a limited company registered registered in England, company number 10586136. We own the HeadForwards On-Demand Platform and all of the intellectual property rights in the Programme. We are responsible for your personal data.

To contact us, please email info@head-forwards.com. We are responsible for the data we collect about you and which is stored on our HeadForwards On-Demand Platform and in our records.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data – your first name, last name, username or similar identifier, age range, gender and ethnicity, which will be provided to you by your employer.

• Contact Data – includes your residential or business address, email address, and phone numbers.

• Technical Data – your login data, you time zone setting and location, the devices you use to access the HeadForwards On-Demand Platform.

• Health Data – information relating to your health and wellbeing at the start of the Programme, during its course and in follow up surveys and questionnaires.

• Usage Data – includes information you upload to the HeadForwards On-Demand Platform, exercises you complete, surveys, feedback on the course, personal development information/feedback, number of learning download entries, number of actions recorded and completed.

• Marketing and Communications Data – includes your preference in receiving marketing from you and your communications preferences (if any).

2. How we use your personal data

We will only use your personal data for the purpose for which we collected it which include the following:

• To register you as a participant on the Programme.

• To use your data, in an anonymised format for our own internal purposes and to support clinical research that we undertake from time to time. We may publish the results of analyses of data for the purposes of dissemination of research providing comparative analysis and reports and marketing. All published information will be anonymous.

• To manage your relationship with us.

• To enable you to participate in questionnaires and take part in surveys both during, and at any anytime in the six months following the end of, the Programme.

• To improve our website, our Programme and our HeadForwards On-Demand Platform.

• To recommend other interactive programmes, webinars, seminars or other services which may be of interest to you.

• To report to your employer if you have not completed the course.

3. How long do we retain your personal data?

All information you upload to your designated area of the HeadForwards On-Demand Platform will be deleted on the earlier of ten months after the end of the Programme or within 5 days of your giving us written notice that you no longer wish to participate in the Programme. If you give us notice to cease we shall be automatically allowed to notify your employer.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes or to be included in material we may publish from time to time, in which case we may use this information indefinitely without further notice to you.

4. How we share your personal data

We may use information that we have taken from surveys, questionnaires and feedback, whether written or verbal, which you provide to us and we shall use this to publicise our research, development and marketing purposes. The use of any such information will always be on an anonymised basis.

Our HeadForwards On-Demand Platform is hosted on the website (https://ondemand.head-forwards.com/login) which is managed by Mole Productions Limited (on behalf of Mind Strength for Business). The website is cloud based and cloud services are provided by Amazon Web Services Inc. In order to manage the operation and functionality of the HeadForwards On-Demand Platform, your user permissions and your designated area, we have granted Mole Productions Ltd permission to access our HeadForwards On-Demand Platform. They are able to access and view all content on our HeadForwards On-Demand Platform only. They have no right to use, view, copy, transfer or otherwise transmit any of the data you upload to your designated area within the HeadForwards On-Demand Platform. Their access to the HeadForwards On-Demand Platform will be restricted to ensure its operation and functionality and to provide certain Helpdesk functions.

We provide feedback analysis to your employer on an anonymised basis based on aggregated data we obtain from all user activities. Your employer will also nominate an administrator who will have access to the HeadForwards On-Demand Platform and will be able to directly access reports which will show your activity within the site. The administrator will not be able to access the content of your secure designated work area.

We may share your personal data with the parties set out below to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We will not transfer, store and process your personal data outside the European Economic Area.

6. Acceptable use of our HeadForwards On-Demand Platform

You may use your designated area of the HeadForwards On-Demand Platform only for your participation in the Programme.

You may not use the HeadForwards On-Demand Platform:

• In any way that breaches any applicable local, national or international law or regulation;
• In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect;
• For the purpose of harming or attempting to harm minors in any way;
• To bully, insult, intimidate or humiliate any person;
• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware;
• To upload or refer to any material which is obscene, offensive, hateful or inflammatory, or which promotes violence or discrimination based on race, sex, religion, nationality, disability, sexual orientation or age or is otherwise deemed by us to be unsuitable.

If you breach any of the above, we may take such action as we deem appropriate, including (but without limitation):

• Immediate, temporary or permanent withdrawal of your right to use our HeadForwards On-Demand Platform;
• Immediate, temporary or permanent withdrawal of any material we consider is inappropriate;
• Issue a warning to you;
• Disclose such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above and we may take any other action we reasonably deem appropriate.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

More detail can be found in the Legal Rights Notice which is available on the HeadForwards On- Demand Platform.

8. Disclaimer

Our Programmes are designed to help people to increase their understanding about their mental health and develop healthy habits to support their psychological wellbeing. We do not provide clinical advice or treatment for people experiencing psychological health difficulties.

© mindstrengthforbusiness Ltd 2023

Version 09082023