- [IMPORTANT INFORMATION AND WHO WE ARE]
- [THE DATA WE COLLECT ABOUT YOU]
- [HOW IS YOUR PERSONAL DATA COLLECTED?]
- [HOW WE USE YOUR PERSONAL DATA]
- [DISCLOSURES OF YOUR PERSONAL DATA]
- [INTERNATIONAL TRANSFERS]
- [DATA SECURITY]
- [DATA RETENTION]
- [YOUR LEGAL RIGHTS]
1. Important information and who we are
Nexus’ commitment to you
We place the integrity and control of your personal information at the centre of the Nexus business and Platforms. As a Nexus User you will be able to manage your Nexus Account settings and preferences, so that you only receive the information relevant for you and only hear about products and services with your permission.
We will request information about your health and well-being, for the purpose of you being able to better understand your current health status, and then be empowered to take decisions on how to improve or change this. The collection of this sensitive data is always subject to your consent and you may control its use at all times- see Sensitive Data.
What this Policy is about
This Policy also explains how and when information may be shared with our Affiliates and Partners if you want to engage with them directly and purchase their products or services.
This Policy also covers our use of your data if you work for one of our Affiliates, Partners or suppliers. This policy also sets out when we may communicate with you in relation to our services and business.
Not intended for children: The Nexus Platforms are not intended for children and we do not knowingly collect data relating to children.
Please contact us at email@example.com if you have any questions or would like further information.
Nexus Digital is the Data Controller under data protection law, and this means we are responsible for determining how and why personal information provided to us is processed, as well as keeping it secure.
Email address: firstname.lastname@example.org
Postal address: Data Privacy Manager, Nexus Digital Technology Ltd, L2-8 Ivy Business Centre Crown Street, Failsworth, Manchester, England, M35 9BG
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes and this can be done through your Nexus Account for all Nexus Users.
2. The information we collect about you
Personal data, or personal information, means any information about you from which you can be identified.
We may collect, use, store and transfer different kinds of personal data about you, depending on why you are engaging with us:
Each time you use our Nexus Platforms we may automatically collect the following information:
- technical information, including (but not limited to) the type of device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting;
- information either accessed through your device or stored on your device which you have explicitly consented to sharing, including where the data comes from and when it was collected; and
- details of your use of the Nexus Platforms and referrals to Affiliates.
A Nexus User is someone who has opened an account with Nexus via one of the Nexus Platforms (Nexus Account). If you are a nexus User, we may process the following personal information about you:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Profile Data includes your basic account information; username password and access information; photos you may choose to upload; other information you may provide in response to a questionnaire or survey; any referrals you choose to Affiliates; support queries and complaints raised; your interests, preferences and feedback and survey responses; any other information you provide to use in relation to your Nexus Account.
- Marketing and Communications Data includes your preferences in receiving marketing from us, any third parties and your communication preferences, including registering for our newsletter.
- Health and Well-being Data:
If you work for an Affiliate, Partner or supplier
In order to collaborate, receive each other’s products or services, we may need the following information about you in order to communicate with you about your work or organisation.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
We also collect, use and share Anonymised Data such as statistical or demographic data. Anonymised Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users interested in a particular affiliate service.
We may use Anonymised Data of Nexus Users of our users to better understand our products, review health and wellbeing needs and patterns more widely, as well as conducting research. This helps us provide and tailor products and services which are relevant for Nexus Users. For example, we might learn that lots of people in one city are interested in running, whereas in another city it is more about going to the gym. We might also learn where people have certain conditions, for example depression or weight management issues.
Research organisations, academic institutions and health organisations are interested in this kind of data because it helps to plan the best services for people in those areas. It is not linked to you personally, and we do not identify you.
Health and Well-being information (Sensitive Data)
Sensitive Data (also known as Special Categories of Personal Data) includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data)
For Nexus Users, we do collect Sensitive Data about you, when you open a Nexus Account and choose to complete the Health and Well-being Questionnaire, or if you respond to further surveys and questionnaires as a Nexus User. This is for you to build up your Nexus Record with relevant information on your health and wellbeing interests and priorities.
If you have set your preferences so you may receive information on suggested and relevant well-being activities and services, we will contact you and keep you informed on these. We will also use the information in your Nexus Record to help tailor these suggestions to you. You may control your settings and these suggestions at any time in the account settings.
Affiliate Products by their nature may constitute Sensitive Data about you, for example if you have purchased a treatment for a bad back or bought a blood test, this will be medical information about you. We track information on the Affiliate Products and web links a with whom you connect, to manage transactions and to tailor suggestions of products and services to you (if selected). We would also like to add the information on the Affiliate Products you purchase or use, so you can build up an accurate and up to date Nexus Record covering your health and wellbeing. However, your consent will be requested to share such Sensitive Data, by the Affiliate or us, before any of the purchase or service information is shared and added to your Nexus Record.
Research Projects and Studies will be made available or suggested to you if you have agreed to be contacted about these in your Nexus Account settings.
If you are not a Nexus User, we do not usually collect Special Category Personal Data about you.
If you fail to provide personal data
Where we need to collect 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 or provide you with our services if you have been referred by a client. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal information directly when you communicate with us. This includes personal data you provide when you:
- open a Nexus Account as a Nexus User;
- complete our Health and Wellbeing Questionnaire or other surveys and questionnaires.
- when you email, phone, or communicate with us via Nexus Platforms;
- enquire about or discuss our services;
- you interact with us and our Affiliates when enquiring about or purchasing Affiliate products and services;
- subscribe to our newsletter or mailing list;
- request marketing to be sent to you;
- when you supply services or goods to us;
- When we partner and collaborate as Affiliates and Partners in order to provide and supply products and services;
- respond to a survey or provide feedback.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
- From Affiliates and Partners in order to manage collaborations, transactions and business interests
- From Affiliates and Partners with your consent when it relates to your Sensitive Data
- From research or academic organisations when you have agreed to take part in a study or trial.
Technical Data from the following parties:
- Analytics providers such as Google based outside the EU;
Profiling and Automated Decision Making. Please note, we do not currently use software to automatically assess your usage or personal data in order to determine more information about you or your characteristics (known as Profiling). Neither do we take automated decisions about you based on the personal data we hold, which may have a significant impact on your rights and freedoms (known as Automated Decision Making). We will update this Policy and other privacy information in the event this changes.
4. Affiliates and Partners
Affiliates: We have relationships with selected Affiliates, covered by relevant contracts, under which we can suggest and offer relevant Affiliate products and services to you. These Affiliates are chosen for their relevance and experience in health and well-being services, as well as social prescribing. These Affiliate products are made available generally on Nexus Platforms, but you may receive personalised and tailored information on Affiliate products if you have selected this on registration or within Nexus Account settings.
When you are interested in an Affiliate product or service you can just click the link, image or advert and be directed to their website. We track that you have done this, so that we are able to understand the products and services you are interested in, so that we may better manage our Nexus Platforms and services. However, we do not share any personal information with the Affiliates without your permission.
We may receive commission or charges from our Affiliates if a Nexus User purchases and Affiliate product of service. Therefore, we receive high-level confirmation of transaction information from an Affiliate, so we are able to manage our business and receive payments for commission due. This data is the minimum required to confirm the purchase and we do not receive any Sensitive Data from an Affiliate to do this.
Our Affiliates may also request your consent to share information with us confirming what purchase you have made and, in some circumstances, the outcome or the service or product. This is for the benefit of building up your Nexus Record, but will be subject to your consent at that time.
Partners: We have relationships with other organisations where we have agreed to collaborate or partner with them in relation to our services and Nexus Platforms. These are usually either:
- research, health or academic bodies, or commercial organisations with whom we are jointly undertaking a research, trial or study; or
- commercial organisations or health institutions who have adopted our services and arranged access to and licences for our Nexus Platforms, for their personnel or patients.
In relation to Partners, statistical information is usually processed on an anonymous or aggregated basis. If we process your personal information, it will be because you have opened a Nexus Account or have given us your consent at that time.
5. Third-party links
6. How we use your personal data
On what basis will we process your information? 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:
- Where we need to perform the contract we are about to enter into or have entered into with you- for example when you open a Nexus Account and engage our services.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests- for example tracking the purchases and transaction information with our Affiliates. When we rely on legitimate interests we will weigh up the use and the reason for it, as well as any benefits, alongside your rights and freedoms, before we go ahead with the processing.
- Where we have your consent- for example when we process your health and well-being information, or confirm you want to hear about relevant activities and services.
- Where we need to comply with a legal obligation.
- Where we need to act to protect your vital interests.
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, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 for further information.
|Purpose/Activity||Type of data||Lawful basis|
|To open your Nexus Account||About whom you are and how to contact you.
|To perform a contract with you (i.e. access our service.
Necessary for our legitimate interest.
|To collect information via the Health and Wellbeing Questionnaire and other health surveys||Information about you and your health and well-being (Sensitive Data)
|(a) With your consent.|
|To provide you with information on relevant activities and services in the well-being sector, including those offered by our Affiliates.
|Information about you, your interests and likes in relation to health and well-being services.
|(a) With your consent
(b) Necessary for our legitimate interest in order to provide our services to you and other Nexus Users.
|To add information on the Affiliate products and services you purchase or use, to your Nexus Profile||Information on who you are, your interests and profile information. This may include health and well-being information (Sensitive Data)||(a) With your consent, obtained by the Affiliate or by us.
|To manage our collaborations with our Partners, which may include providing you with access to our services and Nexus Platforms.||Information about you, who you are, where you work and your contact information.||a) Necessary for our, or our Partners’, legitimate interest in providing products.
b) To perform a contract with you as a Nexus User.
|To refer, enrol or support you as a participant in a research, health or academic study or trial.
To suggest to you studies or trials which you may be interested in.
|Information on who you are, how to contact you, your interests and profile information. This may include health and well-being information (Sensitive Data)||a) With your consent
(b) Necessary for our legitimate interest in order to understand the relevance of such projects, trials and our Partner relationships.
|To manage Affiliate relationships, receive services, goods and other supplier inputs, including:
(a) Manage payments, fees and charges
(b) manage performance of services and delivery of goods
|Contact information and financial/transaction information if engaging with us on your own behalf.
|(a) Performance of a contract with you or your employer
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with Nexus Users which will include:
(b) Asking you to provide feedback or take a survey
|Information about who you are and how to contact you.
Information relating to your Account profile and preferences/settings on marketing and communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(c) consent in some instances for marketing.
|To administer and protect our business and Nexus Platforms (including troubleshooting, fraud prevention, data analysis, testing, system maintenance, support, reporting and hosting of data)||Information on who you are, how you use or Nexus Platforms, what devices you use. Information on how you use our services.||(a) Necessary for our legitimate interests (for running our business, improving our services, providing relevant information on activities and services, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant Nexus Platform content to you and measure or understand the effectiveness of our website and services. To offer you other services, products and Nexus Platforms||Information about who you are your profile with Nexus. This may include health and well-being information (Sensitive Data).
Information on how you use our Nexus Platforms
|(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our strategy).
(b) With your consent when processing your health and well-being information.
|To use data analytics to improve Nexus Platforms, products/services, marketing, client relationships.||Information about how you use our Nexus Platforms, what devices you use and other technical information.
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our strategy)|
|To make suggestions and recommendations to you about services, Affiliate relationships and Partner arrangements that may be of interest to your employer||Information about who you are, how to contact you and who you work for.
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We will use the information in your Nexus Account to propose activities, services and products which may be of interest to you, if you have agreed to this on registration/in your Account settings. Otherwise, we make information on our Affiliate products available generally on the Nexus Platforms.
We do contact and market to organisations which we believe may be interested to be an Affiliate or Partner, or otherwise engage with us. As such, we may contact you using your business contact information in order to discuss this with you or your employer. We rely on our legitimate business interests to do this.
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Nonetheless, we strive to provide you with choices regarding any marketing communication and you will be able to opt out of any communications. We operate a suppression list to ensure we can manage this process, which means we keep the minimal personal data necessary to ensure we do not contact you again.
Nexus Users can manage their communication preferences within the Nexus Account settings.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase or other transactions.
We do not share your information with Affiliates or other third parties for marketing purposes without your prior consent.
Cookies consent may be requested by an Affiliate when you click through or link with their product or websites.
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 us.
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.
7. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal third parties such as our employees or officers and legal entities within the Nexus group of companies.
- With Affiliates and Partners.
- With research and trial partners, being commercial research, health and academic organisations.
- External third parties including clients, payment providers, specialist IT support, cloud hosting providers, communications partners and sub-contractors.
- Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Credit reference agencies, law enforcement and fraud prevention agencies.
- HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- 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.
8. International transfers
We do not usually or regularly transfer data outside of the UK in the course of our business. In the event we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (including the EEA as at the date of this version of the Policy).
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK, as well as conducting an appropriate risk assessment.
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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
For Nexus Users we usually retain some of your personal data, which may include Sensitive Data, for a period of 6 years after you have finished using our services. This is the minimum information required to ensure we can provide relevant information to you and respond to any queries, complaints or claims.
If you are an Affiliate, Partner or other supplier, we usually keep information for 6 years after the last purchase or invoice, however, though this is usually organisational information and any personal data is just retained on an ancillary basis (e.g. your name is on an invoice)
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will receive your data on an anonymous basis from our clients or we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully objected to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. Nexus Users can manage some consents given through the Nexus Account settings. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us and/or check you Nexus Account settings.
No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we could 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). We may also contact you to ask you 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 could 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.