Privacy Policy

Thank you for taking the time to review our Privacy notice. eeda™ are committed to protecting your personal data and respecting your privacy, and this Privacy notice is intended to explain how we protect and your rights to privacy. If you still have questions at the end of reading this Privacy notice, please contact us as hello@eeda.io.

Purpose of this Privacy notice

We know how important it is that we explain who we are, what data we process, and how we protect your data. It is also important to explain your rights in relation to your personal data. That's the purpose of this Privacy notice, so let's get started 🙌.

About this Privacy notice

This Privacy notice (together with our end-user license agreement (the EULA) are presented to you when you first use or install our Platform. It applies to your use of all versions of our Platform, whether available to you as an app on your phone (Mobile Platform📱) or online through our website (Web Platform 💻).

It also applies once you have downloaded or streamed a copy of the Platform onto your personal computer, mobile telephone or handheld or other suitable electronic device (Device).

Any other interactions with us, by phone or computer or otherwise, this Privacy notice will govern the way we process your personal data.

Please note that our Platform is not intended for use by, or for the purpose of the collection of any personal data relating to, children (under the age of 16 years) and we do not knowingly collect data relating to children.

Ok, so let's explain a little about who we are, and how this relates to the way we will process and handle your personal data.

WHO WE ARE

eeda™ is a company trading under the business THE CATEL GROUP LTD, with company number 13151884), with offices at Ap. 9 St. Augustine's Church, 17 St. Augustine's Road, Cheadle Heath, Greater Manchester, SK3 0JN, United Kingdom. We are the data controller who is responsible for your personal data (collectively referred to as, “we“, “us” or “our” in this Privacy notice).

We have appointed a data protection lead (DPL).

Our DPL's contact details are:

• - Name or title of DPL: Gary Hibberd
• - Email address: hello@eeda.io
• - Postal address: Ap. 9 St. Augustine's Church, 17 St. Augustine's Road, Cheadle Heath, Greater Manchester, SK3 0JN, United Kingdom.

CONSENT

Before we can process your personal data, we need a lawful basis to do so. Therefore, we need to seek your permission to do this, and this is known as seeking ‘Consent'. Therefore, before accessing the Platform, you will be asked to indicate your consent to our processing of your personal data.

How you can withdraw consent

Once you provide consent for us to process your personal data, you may change your mind and withdraw consent at any time by emailing us (hello@eeda.io). Please be aware that this will not affect the lawfulness of any processing carried out before you withdraw your consent, and we may still need to retain certain information for an analytics purposes.

We will delete any information that we do not strictly need to comply with our own legal obligations as we are required to by data protection laws. We shall not be able to remove any data that you provided that we have already fully anonymised as part of an aggregated data set (which we describe below) that doesn't reveal any individual's identity.

If you withdraw consent for us to use your data, we will also be unable to provide other Services to you.

THE DATA WE COLLECT ABOUT YOU

Depending upon our interactions, we may collect, use, store and transfer different kinds of personal data about you, including:

We will only ask for your consent again if the purpose of our processing changes.

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Identity Data: first name, last name, username or similar identifier, age, gender, work start date, work from home/work from office, disability, ethnicity.

Contact Data: email address

Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

Content Data: includes log-in information stored on your Device and any digital content that you upload into the eeda™ Platform (e.g. your profile photo)

Profile Data: includes your username and password, your interests, preferences, feedback, rewards earned, response types/times and survey responses.

Usage Data: includes details of your use of any of our Platform or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, and the resources that you access.

Marketing and Communications Data: includes your preferences in receiving marketing communications from us.

App Data: includes whether you are accessing the Platform through a mobile application.

AGGREGATED DATA AND ANONYMISATION 🤫

Ok, this is the technical part, but it's important that you understand how we use aggregated data, and how this is processed.

We may collect, use and share aggregated data such as statistical or demographic data, departmental or engagement thematic data, for the purpose of providing your employer with an anonymised summary of the workforce engagement. Aggregated 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 Data to calculate the percentage of users accessing a Platform feature, or percentage of the team that are engaged or disengaged. 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.

THE CATEL GROUP LTD. And eeda™ are not liable or responsible for any users or employee welfare. We will not share content or alert companies on the data we receive. We cannot be held responsible for any text which may contain personal, harmful, violent, sexual or illegal nature.

We may also use anonymised data for research and scientific purposes in order to either try and improve the way we deliver our own services. This simply means that the data cannot be directly linked back to you, as the data is ‘anonymous'.

We will either rely on legitimate interests or explicit consent as a lawful basis for the anonymisation of your personal data.

HOW IS YOUR PERSONAL DATA COLLECTED? 🗄️

We primarily collect and process your data in the following ways.

Information you provide to us.

Information we collect about you and your device.

We also use Cookies 🍪 (no, not the chocolate chip kind). Cookies are small files which are placed on your device which can improve site performance and your experience while using our Platform. We don't use any tracking cookies, just those mandated by the nature of the website detailed below.

For detailed information on the cookies, we use and the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see the details below:

Cookies

Information we receive from other sources including third parties and publicly available sources.

• - Device Data from analytics providers such as Google based outside the EU;
• - Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Inc based in the United States of America, GoCardless and Xero.
• - Identity Data, Contact Data, Health Data (Special Category), Financial Data, Transaction Data, Device Data, Content Data, Profile Data, Usage Data, App Data, Marketing and Communications Data from our third-party IT services providers or mobile application marketplaces who manage and run our Platform and the Services under our strict instructions and not for their own purposes.
• - Identity Data, Contact Data from your employer to verify your employment status with them.
• - Identity Data, Contact Data from an Authorised User to provide you with access to our Platform via the Friends and Family scheme.

Unique application numbers

HOW WE USE YOUR PERSONAL DATA

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

• - Where you have consented before the processing;
• - Where we operate under a contract which we are about to enter or have entered with you;
• - 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;
• - Where we need to comply with a legal or regulatory obligation; and
• - To protect your vital interests where you are unable to give consent.

When we collect personal data through our digital platforms and website, we will use the information in the way described above and we will make it clear what we intend to do with it.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

When you provide us with your personal data, we may share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

1. 1. External Third Parties as set out in the Glossary.
2. 2. Specific third parties such as Stripe, Inc, GoCardless and Xero.
3. 3. 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.

Who we WILL NOT share your Personal data with:

• - Your employer or the group or organisation to which you belong.
• - Third party marketing providers or databases.
• - Anyone outside of our business, unless and until we have made sure that you can't be identified from the data we create (except as expressly set out in this Privacy notice).

For more information on how this data is used after it is no longer “personal data” see the section on “AGGREGATED DATA” above.

MARKETING

We do not share your personal data with any third party for marketing purposes.

INTERNATIONAL TRANSFERS ✈️

We may transfer your personal information outside the United Kingdom (UK) and European Economic Area (EEA). Whenever we transfer your personal data out of the EEA or UK to a country that has not been deemed to provide an adequate level of protection for personal data by the European Commission, we ensure a similar degree of protection is afforded to it by using specific contracts approved for use in the UK which give personal data the same protection it has in the UK (these are called the Standard Contractual Clauses).

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

DATA SECURITY

We have put in place appropriate operational and technical 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 and legitimate need. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality, and appropriate contracts and non-disclosure agreements (NDA).

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.

DATA RETENTION

Your Personal Data is retained only for the duration that you have an active account with eeda™. Your personal data is securely deleted when;

YOUR LEGAL RIGHTS

You have the following rights under data protection laws in relation to your personal data:

• - access to your personal data,
• - correction of your personal data,
• - erasure of your personal data,
• - restriction of processing your personal data,
• - transfer or your personal data,
• - withdrawal of your consent and;
• - object to processing of your personal data.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

For further information see the paragraph below entitled ‘YOUR LEGAL RIGHTS'.

You can exercise any of these rights at any time by contacting us at hello@eeda.io.

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 or another competent supervisory authority of an EU member state if the Platform is downloaded outside the UK and you are not a UK citizen.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review to ensure that any changes in legislation is reflected here.

This version was last updated in February 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email when you next start the Platform or log onto one of the Platform Sites. The new Privacy notice may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data and Identity Data.

Please check their policies before you submit any personal data to these websites or use these services (I doubt they'll be as good as ours ☺).

Thank you for taking the time to read this privacy notice, and we hope it explains how we will protect your personal data, and your rights. But if you have any questions please contact us.

GLOSSARY

Finally, if any of the terms above were confusing, then we hope the following will clarify them for you.

1. LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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

Protecting your vital interests means processing your data where your vital interests are at stake, such as in an emergency situation, where we would consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data pursuant to this justification.

2. THIRD PARTIES

2.(A) EXTERNAL THIRD PARTIES

Service providers acting as processors who provide IT and system administration services such as but not limited to mobile application marketplaces, cloud software, and mobile operating systems.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

3. YOUR LEGAL RIGHTS

You have the right to:

• - 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 exercised your right to object 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 particular 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:
• - (a) if you want us to establish the data's accuracy;
• - (b) where our use of the data is unlawful but you do not want us to erase it;
• - (c) 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; or
• - (d) 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. 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.

End of Privacy Notice.