Effective date: 16 August 2018
This privacy notice is for people who use this SilverCloud website and for people who we communicate with for marketing purposes.
We respect your privacy and will treat your data in accordance with the EU General Data Protection Regulation, the Data Protection Act 2018 and other applicable data protection and e-privacy law.
When we collect or use your data, SilverCloud is the “data controller”, which means we decide how and why your data is processed. Contact details for SilverCloud are listed at the bottom of this notice.
There is a separate privacy statement for people who use the SilverCloud platform and programmes.
Your data is collected by SilverCloud in a few ways:
Here is a list of the categories of personal data that are collected and used, with examples.
Contact details
Your name, company, role, email address, telephone number, postal address, etc.
Enquiry data
Type of enquiry, text of enquiry
Data about your use of our website and emails
IP address, unique identifiers, browser type and version, time zone and language, pages viewed
Data we do not collect
Children's data
SilverCloud is intended for use by adults aged 18 years or over and we do not knowingly collect personal data from people under 16 years of age.
Special category data
SilverCloud does not process “special category data” such as health data through its website or its email services.
If you are looking for help and want to use the SilverCloud programmes, please contact your local mental healthcare provider to see if SilverCloud or other suitable services are available in your area.
SilverCloud processes your data for specific purposes and where there is a legal basis.
We use your contact details and enquiry details to respond to your enquiries. If you send a sales enquiry we will add you as a business contact.
Legal basis: contract, legitimate interests
We communicate with business contacts (i.e. existing or potential customers) about relevant products or services.
We also collect business contact information from third parties who manage relevant business contact databases.
We will not sell, distribute or lease your personal data to third parties. We do not directly market to SilverCloud platform clients or other individuals (i.e. business-to-consumer).
Legal basis: legitimate interests
SilverCloud records data and uses analytics tools to help analyse how users use the site.
Legal basis: legitimate interests
This explains the legal bases mentioned above
Contract
Processing your data is necessary to fulfil a contract or before entering a contract.
Legitimate interests
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. Our legitimate interests include:
These interests may be overridden by your rights and interests.
Cookies
This website uses cookies. You can find information on how to use browser settings to stop unwanted cookies here.
Marketing
You can opt out from marketing by emailing enquiries@silvercloudhealth.com or by using the unsubscribe links in any marketing emails you have received.
You have rights regarding your personal data. If you have any questions please contact dataprotection@silvercloudhealth.com
Right to information about processing of your personal details
The aim of this privacy statement is to give you this information.
Right to access your personal data
You have the right to know if your personal data is being held, what categories of data are held, and to receive a copy of all data about you.
Right to change or remove your details
You have the right to correct any inaccurate data, or remove data if it is not necessary for us to hold it.
Right to object to processing
You can object to processing for direct marketing (opt-out), or if it could otherwise affect your rights, freedoms or interests.
Right to data portability
While we do not process your data on the basis of consent, we will provide your data in a portable format.
Right to lodge a complaint
You also have the right to lodge a complaint with a supervisory authority, although we encourage you to contact SilverCloud first.
Contact details for the Data Protection Commission can be found at https://www.dataprotection.ie/
You may have also heard about the following rights, however we believe they are not relevant to SilverCloud’s use of your data
Rights in relation to automated decision making: we do not use automated decision making with legal or other significant effects
Right to withdraw consent: we do not process your data on the basis of consent
We use third parties to host our website, analyse usage and communicate with you
Hosting
Amazon Web Services EMEA SARL, 5 rue Plaetis, L-2338 Luxembourg
We use Amazon Web Services to host the wesite.
Data: Data about your use of website
Location of processing: US and EU
Analytics
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States
We use Google Analytics to help analyse how users use the site.
Data: Data about your use of website
Location of processing: US and EU
Marketing
The Rocket Science Group LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA
We use MailChimp to store contact details for our mailing lists and to send marketing emails
Data: Contact details, Data about your use of emails
Location of processing: US
Hubspot Ireland Limited, Ground Floor, Two Dockland Central, Guild Street, Dublin 1
We use HubSpot to store contact details for our customers and potential customers, to send marketing emails, to host website landing pages and blog
Data: Contact details, Data about your use of emails and website
Location of processing: US
Wilmington Healthcare Limited, Beechwood House, 2-3 Commercial Way, Christy Close, Southfields, Basildon, Essex, SS15 6EF, UK
We use Wilmington Healthcare to provide us with lists of business-to-business contacts
Data: Contact details
Location of processing: EU and also US, Dubai, Singapore and Hong Kong
Sproutwell Developments LLC dba SalesBetty, Chicago, IL 60614, USA
We use SalesBetty to provide us with lists of business-to-business contacts
Data: Contact details
Location of processing: US
Cognism Limited, 12 Times Court Retreat Road, Richmond, England, TW9 1AF, UK
We use Cognism to provide us with lists of business-to-business contacts
Data: Contact details
Location of processing: US
TINDERPOINT LTD., The Warehouse, 26A Mount Eden Road, Donnybrook, Dublin 4, Ireland.
We use Tinderpoint to support our marketing efforts.
Data: Contact details
Location of processing: Ireland
Inspired Thinking Group (ITG) Ltd., The Warehouse, 26A Mount Eden Road, Donnybrook, Dublin 4, Ireland.
We use ITG to support our marketing efforts.
Data: Contact details
Location of processing: Ireland
You should also be aware that where you link to another website from the SilverCloud website, that SilverCloud has no control over that other website. Accordingly, SilverCloud cannot guarantee that the controller of that website will respect your privacy in the same manner as SilverCloud.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
SilverCloud maintains ISO 27001:2013 certification.
Personal Data shall be retained only in accordance with the Data Retention requirements of SilverCloud's Privacy Policy.
We will revise this privacy notice when necessary and we encourage you to check back in future for changes.
If you wish to contact SilverCloud regarding our use of your Personal Data or to exercise your rights, please contact us at:
SilverCloud Health
One Stephen Street Upper
Dublin 8
Ireland
dataprotection@silvercloudhealth.com
SilverCloud's Data Protection Officer (DPO) is BH Consulting:
SilverCloud Health Data Protection Officer
BH Consulting
The LINC Centre
Blanchardstown Road North
Dublin 15
Ireland
dataprotection@silvercloudhealth.com