Effective date: 13 November 2020
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.
Your name, company, role, email address, telephone number, postal address, etc.
Type of enquiry, text of enquiry
IP address, unique identifiers, browser type and version, time zone and language, country, pages viewed
Event registration details include first name, surname, email and job title. We may also video record the events for future uses.
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.
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 classify and rate business contacts based on relevant criteria such as business sector, role, and other factors, which can be considered profiling, through statistical and machine learning processes.
We customise the content shown to users of the website based on your preferences, location and use of the website.
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
We record event registrations to allow us to manage and run events, ensure we have capacity and share information regarding the event.
Legal basis: legitimate interests
This explains the legal bases mentioned above
Processing your data is necessary to fulfil a contract or before entering a contract.
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.
This website uses cookies. You can view our Cookie Declaration page for details. You can find information on how to use browser settings to stop unwanted cookies here.
You can at any time change or withdraw your consent from the Cookie Declaration page on our website.
You can opt out from marketing by emailing enquiries@silvercloudhealth.com, by using the unsubscribe links in any marketing emails you have received or by unsubscribing here.
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
Hubspot Ireland Limited, Ground Floor, Two Dockland Central, Guild Street, Dublin 1
We use Hubspot to host the website.
Data: data about use of website
Location of processing: US
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: North America, Chile, Ireland, Netherlands, Denmark, Finland, Belgium, Taiwan, Singapore (https://www.google.com/about/datacenters/locations/index.html)
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States
We use Google Adwords to advertise on our products and services on Google search results and third party website.
This website also uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This could mean that we advertise to previous visitors of our website based on their behaviour on the website. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the SilverCloud Health website. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.
Data: data about users behavior on our website; contact emails.
Locations of processing: North America, Chile, Ireland, Netherlands, Denmark, Finland, Belgium, Taiwan, Singapore (https://www.google.com/about/datacenters/locations/index.html)
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
LinkedIn EMEA Head Office Gardner House, 2 Wilton Pl, Grand Canal Dock, Dublin
We use LinkedIn to advertise to prospects (LinkedIn users), to our list of email contacts (Matched Audiences) and to our website visitors (Website Retargeting)
Data: Contact details, Data about your use of the website
We use LinkedIn Forms to voluntarily collect contact information from business prospects on the LinkedIn platform. A LinkedIn member who accesses a Form can choose to disclose their contact information to SilverCloud and consent to use of the information for marketing purposes.
Data: email address, name, job title, organization, LinkedIn member ID
Location of processing: EU
155 5th St, 7th Floor, San Francisco, CA 94103
We use Eventbrite to manage event registrations.
Data: first name, surname, email and job title
Location of processing: US and EU
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
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