Terms of Service and Privacy Policy
Cookie Notice
Effective Date: [4th June 2021]
This Cookie Notice (“Notice”) applies to all websites (including www.heyr.app) mobile applications (including Jesey Wellbeing Assistant) and other products and services (collectively, “Services”), that are owned and operated by Jesey-AI Ltd of Kemp House, 160 City Road, London, UK, EC1V 2NX (“Jesey”, “we”, “us”, “our”).
This Notice explains how Jesey uses "cookies" or similar technologies on our Services and applies to all individuals who access or use our Services.
When you first access our Services you will receive a message advising you that cookies and similar technologies are in use. By clicking “[Accept]” you signify that you understand and consent to the use of these technologies, as described in this Notice.
We may change this Notice from time to time, so please review this page periodically for changes. The “Effective Date” provided at the top of the page will indicate when the Notice was most recently updated.
You do not have to accept cookies and consent can be withdrawn at any time (see How to Control Cookies, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some areas of the Services that you access may take more time to work or may not function properly.
WHAT ARE COOKIES?
Cookies are small files containing a string of characters that we may store on your computer or mobile device when you access our Services. When you access the Services again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.
Cookies set by a website owner (in this case, Jesey) are called “first party cookies”. Cookies set by parties other than the service provider or website owner are called “third party cookies”. Third party cookies enable us to provide third party features or functionality through our Services (i.e. advertising, social media functions and analytics).
THE COOKIES WE USE
Cookies make the use of our Services easier by, among other things, saving your preferences. We may also use cookies to deliver content tailored to your interests. Our cookies may enable us to relate your use of our Services to personal data that you previously provided.
The information that we collect with cookies allows us to statistically analyze usage of our Services, and to improve and customize our content and other offerings. However, we only disclose information collected with cookies to third parties on an aggregated basis without the use of any information that personally identifies you.
The specific types of first party and third party cookies placed by our Services and the purposes they perform are described in the appendix to this Notice.
HOW TO CONTROL COOKIES
When you first access our Services, you will receive a message advising you that cookies and similar technologies are in use. By clicking “[Accept]” you signify that you understand and consent to the use of these technologies, as described in this Notice.
You do not have to consent to our use of cookies, and where you do consent this can be withdrawn at any time, although you may not be able to use certain features of our Services. You can do this by adjusting your cookie preferences or activating the settings on your browser that allows you to refuse all or some cookies.
Please follow the links below to helpful information for the most popular browsers:
Microsoft Internet Explorer
Google Chrome
Mozilla Firefox
Apple Safari:
In addition, you can exercise advertising cookie choices by visiting:
http://youronlinechoices.com/.
WEB BEACONS
As well as cookies, we use other technologies to recognize and track your use of our Services. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.
Web beacons allows us, for example, to monitor how users move from one page within our Services to another, to track access to our communications, to understand whether users have come to our Services from an online advertisement displayed on a third-party Services, to measure how ads have been viewed and to improve site performance.
HOW TO CONTACT US
If you have any questions, comments, or concerns regarding this Notice or our Services, please email [info@heyr.app] or use the “Contact us” link on our website (www.heyr.app)
Privacy Notice
Effective Date: [4th June 2021]
This Privacy Notice (“Notice”) applies to all websites (including www.heyr.app) mobile applications (including the Jesey Wellbeing Assistant) and other products and services (collectively, “Services”), that are owned and operated by Jesey-AI Ltd of Kemp House, 160 City Road, London, UK, EC1V 2NX (“Jesey”, “we”, “us”, “our”). Jesey is the data controller of personal data that is processed in connection with your use of the Services and we are registered with the Information Commissioner’s Office (“ICO”) as a data controller.
This Notice explains how we collect, use, maintain and disclose information collected about you, including when you visit or use our Services or otherwise interact with us. Your privacy is important to us, and we recognize the importance of protecting information collected about you.
Please read this Notice carefully to understand how we will collect, use, maintain and disclose your personal data. This Notice also describes your choices regarding use, access and correction of your personal data.
CHANGES TO THIS NOTICE
We may change this Notice from time to time. If we make any changes, we will notify you by revising the “Effective Date” at the top of this Notice. In some cases, we may provide you with additional notice (such as adding a statement to our Services, or by sending you an email notification). We encourage you to review this Notice whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of our Services after any change to this Notice will constitute your acknowledgement of such change.
HOW TO CONTACT US
If you have any questions, comments, or concerns regarding this Notice or our Services, please email [info@heyr.app] or use the “Contact us” link on our website (www.heyr.app).
CHILDREN
We do not knowingly collect information from individuals under the age of 16 years without parental consent. If we learn that we have received any information from an individual under the age of 16 without parental consent, we will take steps to remove the data as permitted by law. If you believe an individual under 16 years of age has provided us with personal data without parental consent, please contact us using the contact details contained in the “HOW TO CONTACT US” section above.
INFORMATION COLLECTED
When you use or access our Services or otherwise interact with us, we may collect a variety of information about you and others, as described below. Such information includes, but is not limited to, information about you which is in a form that permits us to identify you (your “personal data”).
Information you provide to us. We collect information that you provide to us, or that someone on your behalf provides to us. For example, when you inquire about our Services, request our marketing materials, create a user account on our Services, access and use our Services (including, but not limited to, if you chat with the Jesey Wellbeing Assistant, request customer support, attend an event, enter a competition or engage with a promotion, join the Jesey community, or communicate with us by phone, email, via third-party social media sites or otherwise. The types of information may include:
Contact data, such as your full name, username or similar identifier (such as your Customer ID), postal address, email address and telephone numbers, social media accounts, etc.
Information about you, such as your age and date of birth, gender, race or ethnic origin, language spoken, education (including the university you attend and any professional training), interests in using the Services, etc.
Credentials, such as passwords, password hints or similar security information used for authentication and account access, etc.
Marketing data, such as your preferences in receiving marketing from us, etc.
Chat data, such as the information you provide when engaging with our chatbot feature, and the content of your communications.
Health and wellbeing data, such as a physical description, your responses to questions about wellness, your “mood score”, etc.
Some of the information that you provide to us is considered special category personal data under data protection legislation and must be given additional protection. Special category personal data includes data concerning your health, data revealing your racial or ethnic origin, data relating to your religious or philosophical beliefs, and data concerning your sex life or sexual orientation.
Information we collect automatically. When you use or access our Services, we may also collect certain information through automated means, including but not limited to some or all of the following:
Device data, such as your mobile phone number, unique device ID, device type, brand and model, the version of the application you are using and the operating system you are using the application on, machine ID, geolocation information, computer and connection information, browser type, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer or device when you use the Internet, which may vary from session to session), domain name, and date and time stamps for your visits. We also may collect any telephone number from which you contact us.
Log data, including information associated with your activities on our Services, information about the way you interact with our Services, the frequency of interactions and when you open notifications, number of sessions and session duration, when you use our Services, statistics regarding your page views and traffic to and from our Services, and the number of bytes transferred, hyperlinks clicked, and other actions you take. We may also track information such as the URL that you visited before you come to our Services and the URL to which you next go.
Account data, including your reward and loyalty points, in-app purchases that you may make, and promotions that you have engaged with.
Cookies and similar tracking technologies. As with most websites and other digital services, we employ cookies, pixel tags, web beacons, and similar technologies to collect and store certain information about visitors to our Services. We use this information to improve our Services, and to help us remember you and your preferences when you next visit our Services. For more information about our practices in this area, please see our Cookie Notice.
USE OF INFORMATION
We process your personal data for the purposes set out in this Notice only where we have a valid legal basis for doing so under applicable data protection law. The precise legal basis will depend on the specific purpose for which we process your personal data. We have set out the most common processing purposes, and our legal bases for these, below:
Where processing is necessary for the performance our contract with you under the applicable terms and conditions for the relevant Service, or to answer questions or take steps at your request prior to entering those terms, including:
to create and maintain your user account and to manage registration with any promotions;
to provide, operate and maintain the Services;
to manage use of the Services, respond to enquiries and comments and provide customer service and support;
to process and complete transactions, and send related information, including transaction confirmations and invoices;
to send technical alerts, updates, security notifications, and administrative communications; and
to respond to requests or inquiries.
Where processing is necessary for certain legitimate interests, of us or another third party, provided such interests are not overridden by your fundamental rights or freedoms, including:
to deal with any enquiries or complaints you or others make, to troubleshoot and diagnose problems, repair issues and provide other customer care and support services;
to confirm, update and improve our records, and to analyse and develop our relationship with you;
for internal administrative and technical operations to keep our Services, network and information systems updated, patched and secure;
to continually improve our Services, including adding new features or capabilities, and to develop new products and services;
to investigate and prevent fraudulent activities, unauthorized access to our Services, and other illegal activities; and
to respond to requests from competent authorities and to protect our interests, rights, safety or property, and/or that of our partners, you or others.
Where we have your consent to process personal data. Such consent can be withdrawn at any time, although this will not affect the legality of processing that has previously been caried out in reliance on this consent. For example:
When you sign up to our marketing list;
Where you freely decide to provide us with additional information, for example when engaging with the chatbot feature in the Jesey Wellbeing Assistant; or
Where you elect to provide us with special category personal data, then your provision of such data constitutes your consent for us to process it in accordance with this Notice. This consent can be withdrawn at any time.
In some limited circumstances, we may also process your personal data where it is necessary to comply with legal obligations to which we are subject, to protect your vital interests, or where it is necessary for the exercise, establishment, or defence of legal claims.
DISCLOSING INFORMATION
Access to your data is restricted to certain technical and administrative individuals within Jesey who need to process your data as part of providing our Services to you. If using the Jesey Wellbeing Assistant application, you may be encouraged to speak to third parties that can help, such as the Samaritans, or a specific department at your university or organisation. While the app may direct you to these third parties, Jesey does not share your personal data with them.
However, there are circumstances where we may wish to share or are compelled to share your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed in this Notice. We may share or disclose your personal data to the following third parties:
Trusted third-party service providers who perform services on our behalf in connection with our Services. The services provided by such third parties include services in the following categories: [processing payments on our behalf, sending marketing communications on our behalf (currently Mailchimp), helping us to create or maintain our applications and databases, helping us to research or analyse visitors to our Services and maintaining the security of our cloud-hosting services, backend support services and data analysis and visualization support services].
Another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event.
A successor organisation or other legal entity, in the case of a merger, financing, acquisition or dissolution, transition, or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
Public authorities and other third parties, to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce other agreements you may have with Jesey, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a reporting agency for fraud protection). We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
Our professional advisors, such as our auditors, accountants, and lawyers.
Any other third party where you have provided your consent.
We may also share aggregated or anonymous information that cannot identify you with third parties. For example, we may disclose general statistics about the mental health and wellbeing of certain populations to organisations that use our Services (e.g. if you have signed up to the Jesey Wellbeing Assistant application and included details about the university you attend, we may share anonymised, aggregated data with the university, such as the general wellbeing of its students). The receiving third parties will not be able to identify you from such data.
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.
RETENTION OF PERSONAL DATA
We will store your personal data for no longer than is necessary for the purpose for which such personal data is processed.
We retain information about our users (including the content of any conversations held with the chatbot on the Jesey Wellbeing Assistant application) for up to 14 months, after which time it is securely destroyed. We may retain other personal data (such as your username and password) for longer in case you wish to make use of our Services in future.
Please note, however, that we may retain and use your personal data as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove such information from our databases, which means that we may retain and use your personal data as necessary after you stop using our Services.
SECURITY AND STORAGE
We ensure the security of any personal data we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information in compliance with standards required by data protection laws. All user messages within the Jesey Wellbeing Assistant application are encrypted in transit and at rest.
All personal data processed by Jesey is processed and stored in the UK or the European Economic Area. We may transfer personal data to third parties located in other jurisdictions and where these jurisdictions do not offer a comparable level of protection of personal data, we will ensure such transfers are protected by an appropriate safeguard. This may include the Standard Contractual Clauses approved by the EU Commission and/or the UK Government. For details of these, and copies, please contact us using the details under the “HOW TO CONTACT US” section above.
YOUR CHOICES
You are not obliged to provide us with any personal data. You can always opt not to disclose information to us, but keep in mind some information may be needed to create a user account or to take advantage of some of our Service features. Other information about you may be collected automatically in connection with your use of our Services.
Marketing communications
We only send you direct marketing communications where you have given us your express consent. Any email marketing messages we send are done so through an email marketing service provider (“EMS”). An EMS is a third party service provider of software or applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as times, dates, IP addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with applicable data protection and privacy legislation. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences, and the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.
Sponsored links, affiliate tracking and commissions
Our website may contain adverts, sponsored and affiliate links on some pages. These are typically served through our advertising partners; Google Adsense, eBay Partner Network, Amazon Affiliates, or are self served through our own means. We only use trusted advertising partners who each have high standards of user privacy and security. However, we do not control the actual adverts seen / displayed by our advertising partners. Our ad partners may collect data and use cookies for ad personalisation and measurement where you have consented to this. Where ad preferences are requested as 'non-personalised', cookies may still be used for frequency capping, aggregated ad reporting and to combat fraud and abuse.
Clicking on any adverts, sponsored or affiliate links may track your actions by using a cookie saved to your device. You can read more about cookies on our Cookie Notice.. Your actions are usually recorded as a referral from our website by this cookie. In most cases we earn a very small commission from the advertiser or advertising partner, at no cost to you, whether you make a purchase on their website or not.
We use advertising partners in these ways to help generate an income from the website, which allows us to continue our work and provide you with the best overall experience and valued information.
If you have any concerns about this we suggest you do not click on any adverts, sponsored or affiliate links found throughout the website. You can also contact us for more information using the details under the “HOW TO CONTACT US” section.
YOUR DATA SUBJECT RIGHTS
In certain circumstances you have rights under data protection laws in relation to your personal data that we hold about you—specifically:
The right to be informed. You have the right to be informed about how your data is collected and used (which is the purpose for this Notice.
The right of access. You may have the right to request access to any personal data we hold about you as well as related information, including the purposes for processing the personal data, the recipients or categories of recipients with whom the personal data has been shared, where possible, the period for which the personal data will be stored, the source of the personal data, and the existence of any automated decision making.
The right of rectification. You may have the right to obtain without undue delay the rectification (or correction) of any inaccurate personal data we hold about you.
The right of erasure. You may have the right to request that personal data held about you be deleted.
The right of restriction of processing. You may have the right to prevent or restrict processing of your personal data.
The right of data portability. You may have the right to request transfer of your personal data directly to a third party where this is technically feasible.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator 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.
LINKS TO THIRD PARTY WEBSITES
Our Services may contain links to other websites that are not covered by this Notice and where information practices may be different from ours. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our Services and go to another website. During this process, another entity may collect information from you. We have no control over, do not review, and are not responsible for the privacy practices or the content of such other websites. Please be aware that the terms of this Notice do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.