Healthy Workers B.V.

Privacy Statement Healthy Workers

Last updated: May 2019

Who are we?


We are Healthy Workers. We have a cloud-based workplace data tool which measures the performance of workplaces (in terms of space, amenities and services and well-being of employees) and subsequent the impact of workplace adjustments. The insights generated are used to make quantified decisions on managing adaptive physical spaces where you and your colleagues can thrive. Healthy Workers improves spaces primarily by giving customers insights into how buildings, systems & services are catering to the people that rely on them. We comply with the General Data Protection Regulation/ Algemene Verordening Gegevensbescherming (jointly the “GDPR”), which has replaced the different national privacy laws of EU member states as per 25 May 2018

Our Services include providing insight into the performance of your work environment, your satisfaction and the well-being at your work, based on data about both you and your work environment. We report the results in the form of an anonymized summary to your employer so that we can help create an optimal work environment for you and your colleagues.

What is this?

This is a Statement. In this document, we explain what kind of Personal Data we process when you use our product, provide feedback and participate in our questionnaires via our mobile application, hereafter: the App. We also explain how we store, protect and use your personal data and for which purposes.



Personal Data

In this Privacy Statement, Personal Data means information or pieces of information that could allow you, a natural person, to be directly or indirectly identified.



Data Controller

We determine the purpose and means of the processing of the Personal Data. Therefore, we act as Data Controller within the meaning of the GDPR. Our clients (employers) do not receive any Personal Data we have collected. Therefore, our clients do not act as Data Controller or as Data Processor.



Which Personal Data do we process and how do we use it?

We may collect and process the following Personal Data from you as a user, when you use our product :


Personal Data Purpose(s) What do we use it for?
First- and last name We ask for your first- and last name to identify you as an individual employee of our client. It is not possible to use pseudonyms, as this enables employees to create multiple accounts – which would lead to distortion of our data analysis We use this data to make sure you recognise that you are logged in by calling you by your name.
Work email address Identification of our users and your Healthy Workers login name. You gain access to the product by using your work email address.
Department and team size To combine data per department, in order to analyse the overall working conditions per department. We need these data to perform our contract with you, i.e. to deliver our Services.
Work environment satisfaction and level of well-being:

Mental well-being

Physical well-being

Overall satisfaction at your work with the current physical environment and all its aspects (e.g. indoor climate, amenities & services)
Analysis of employee satisfaction at work and employee physical and mental well- being at work. We ask for your explicit consent to process these data – namely by agreeing to this privacy policy when creating an account with us. This data is used to measure how satisfied you are with the environment, how you are feeling at work (mentally and physically) and to what extent you are engaged and able to perform in your work environment. Without these data, we are not able to analyse the work conditions and make a useful report for your employer.

We also collect non-personal data about the working conditions at the user’s working place, for example:

These non-personal data can not be traced to an individual and are therefore not Personal Data. The noise sensors only register sound intensity (decibel) and do not register or capture voices. The movement sensors only registers movement, and do not capture images. This means our use of non-personal data falls outside the scope of the GDPR and this Privacy Statement.



For what period will we retain Personal Data?

The Personal Data we process will be deleted when these are no longer necessary for the fulfilment of the purposes mentioned above. In no case we will keep the Personal Data longer than 2 years after the data have been last modified, unless we are legally obliged to keep the data for a longer period. If the user terminates its contract with Healthy Workers, we will remove all personal Data of that users within a month. On request of the user, we may retain the Personal data up to 3 months.



Who do we share your Personal Data with?

In order to render our services, we need to share the personal data with external services. For example, we make use of the services of Google Cloud Services, a global hosting and Web-Application service provider that provides our infrastructure, hosting and security services.


Data Processor Data they process Where they are based Where the data is stored
Google Cloud Services All user- and company-specific data is sent through GCS with TLS encryption. The data is stored encrypted in a cloud-hosted database. Global Location may change dynamically based on location of clients and/or performance reasons
Intercom Textual feedback/questions, possible user contact data : email address of logged in users. Ireland AWS us-east-1
Product Board We collect feedback from our clients/users in Product Board to manage our product development. USA AWS US East 1
Google Analytics Traffic/event analysis on organisational level. USA Europe West 4a
Segment Traffic/event analysis on organisational level. USA USA

Such external services will solely act as Data Processor within the meaning of the GDPR. This means our Data Processors must strictly follow our instructions and is contractually obliged not to use the data for its own purposes. We do not share data with Google Cloud Services or other external services beyond what is necessary to assist us.



Besides the above, we will not share your data with third parties – unless we are legally obliged to do so.



Export of Data outside the European Economic Area

We may transfer the Personal Data outside the EEA, if one of our Data Processors is located outside the EEA under the following conditions. In case we transfer Personal Data outside the EEA, the Personal Data will only be transferred to countries or organisations that provide an adequate level of data protection meeting EU-standards. For example, we will verify if that organization is a Privacy Shield Participant or is listed as third country whose level of data protection has been considered adequate by the European Commission. We want to ensure that any transfer of Personal Data outside the EEA is in compliance with the GDPR.



Generic (non-personal) data

We do not share any Personal Data with your employer. We will convert any Personal Data into non-personal data and combine it with information collected from other users. We use a mix of pseudonymization with secret key encryption, aggregation, and K-anonymity to achieve this. This means that the data will be fully and irreversibly anonymized: they will not contain any Personal Data. Our clients, i.e. the employers, can only access the combined summaries of anonymized company data. Our clients cannot see which employees have or haven’t participated in the questionnaire.



How do we protect Personal Data?

We work hard to protect your Personal Data from unauthorized or unlawful access, alteration, disclosure, use or destruction. For example, we take the following measures to make sure the Personal Data is safe:



Third party websites

You may find advertising or other content on our Website that link to the websites and services of our clients, partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not control the content or the links that Web-Appear on these websites and we are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites that are linked to our Website, are subject to the terms and policies of that website.



Cookies

We may use the following types of cookies on our Website and Web-App:

Analytical (statistical) cookies: we use these cookies to track visitor statistics. We use these statistics to continuously improve the Website / Web-App. These cookies also allow us to recognize and count the number of visitors and to see how visitors navigate when they’re using our Website / Web-App. This helps us to improve user navigation and to ensure users can find what they need more easily.

Tracking cookies: these cookies monitor the clicking behaviour and surfing habits of our visitors. By means of these cookies we can see, for example, whether and when you view your profile and whether you click through to our Website / Web-App. We might use these cookies to show you advertisements based in your interests.

You can change the cookie settings in your web browser if you don’t want cookies to be stored on your device. Please note that some features of our Website / Web-App may not function properly without cookies.



Modifications to this Privacy Statement

We may update our Privacy Statement from time to time. When we change our Privacy Statement in a significant way, we will post a notification on our Website and App along with the updated Privacy Statement.





Your rights

You have the following rights in regards to your personal information:



Access

You have the right to access information about the personal data we hold about you. We reserve the right to charge a reasonable fee in response to unreasonable or repetitive requests, or requests for further copies of the same information.



Right to object to processing

You have the right to object to the processing of your personal data where that processing is being undertaken by us on the basis of our (or a third party’s) legitimate interest. In such a case we are required to cease processing your data unless we can demonstrate compelling grounds which override your objection. You also have the right to object, at any time, to the processing of your personal data by us for direct marketing purposes.



Rectification

You have the right to request that we rectify any inaccurate personal data that we hold about you.



Erasure

You have the right to request that we erase any personal data that we hold about you, based on one of a number of grounds, including the withdrawal of your consent (where our processing of that data is undertaken on the basis of your consent), or if you object to our continued processing (as mentioned above). This right does not extend to information which is not personal data. Please also note that it is likely to be necessary for us to retain your personal data for the purposes of assessing and verifying data that is submitted and/or held on the Platform, and your rights under applicable law to request erasure may be limited accordingly. We also reserve the right to retain your personal data in an anonymised form for statistical and benchmarking purposes.



Request to restriction of processing

This enables you to ask us to restrict the processing of your personal data in certain circumstances, for example if you want us to establish its accuracy or the reason for processing it.



Portability

You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies. You may also request that your personal data is transmitted directly to another organisation where this is technically feasible using our data processing systems.



Change of preferences

You can change your data processing preferences at any time. For example, if you have given your consent to direct marketing, but have changed your mind, you have the ability to opt out of receiving marketing communications by emailing us at support@healthyworkers.nl or clicking the relevant link in any communication you receive.


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 fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.


Please note that if you exercise any of the above rights to require us to restrict or cease processing or to delete personal data, and this type of processing is required in order to facilitate your use of the Platform, you will no longer be able to use the Platform following the date on which we action your request. This does not include your right to object to direct marketing which can be exercised at any time without restriction.


Please allow at least 21 working days for your request to be actioned.


Save as set out above, your rights detailed above can be exercised free of charge in accordance with applicable data protection laws. Please contact your employer directly if you would like to exercise any of these rights (other than a change to your marketing preferences, which should be notified directly to us as described above).


If for any reason you are not happy with the way that we have handled your personal data, you also have the right to make a complaint to the relevant supervisory authority in your country.



Our contact details


Healthy Workers B.V.
Johan Huizingalaan 763A
1066 VH Amsterdam
The Netherlands
E-mail: info@healthyworkers.nl
Chamber of Commerce (Kamer van Koophandel) number: 67322174
VAT number: NL 8569 30 994 B 01