‍Privacy policy for end users

We at Wellbefy AB ("we, "our" and "us") take your privacy very seriously and endeavour to ensure that your personal data is handled responsibly and lawfully. We comply with applicable laws and regulations and that the processing of personal data has been adapted to meet the requirements of applicable data protection legislation, including the General Data Protection Regulation ("GDPR").

In brief

Wellbefy provides its app and web platform (the "Product") to corporate customers. This means that you, as an end user of the Product, are generally an employee or consultant of Wellbefy's corporate customers. When you as an end user use the Product, we process personal data about you in order to provide the Product. When we process your personal data for the purpose of providing the Product, we process your personal data on behalf of our business customers (your employer or client). This means that we are a data processor to our respective business customers (your employer or client), who are data controllers. For this purpose, we have entered into a data processing agreement with our business customers.

We also process personal data about you as an end user of the Product for our own purposes of (i) developing and improving our services, for example to improve our algorithmic formulas in the Product, and (ii) to be able to conduct analyses of trends regarding work environment and health at an aggregated level. These personal data processing operations are carried out by Wellbefy under its own responsibility.

In this privacy policy, you will find information on how we process personal data about you as an end-user of the Product when we process your personal data under our own responsibility.

Personal data is information that can be used to identify you or that can otherwise be linked to you ("Personal Data"). This policy describes how we collect, use and protect Personal Data collected from you, as well as how we profile and manage absence, work and health data that you register in our app (mobile or web).

If you have any questions regarding our processing of your Personal Data, please contact us!

This Privacy Policy was updated 2024-05-07

01. Your agreement

By using our Platform and/or providing your personal information to us, you consent to the collection, use and sharing of your information in accordance with this Privacy Policy. We reserve the right to update this Privacy Policy periodically to reflect any changes in our data protection practices. We recommend that you review this policy regularly to stay informed about how we handle your personal information.

02. Who is responsible for handling your personal data?

When you, as an end-user, use the Product, we process personal data about you in order to provide the Product. When we process your personal data for the purpose of providing the Product, we process your personal data on behalf of our business customers (your employer or client). This means that we are a data processor to our respective business customers (your employer or client), who are data controllers. For this purpose, we have entered into a data processing agreement with our business customers. For information on how your employer or client processes your personal data, we refer you to your employer or client.

We provide our product together with subcontractors who offer different types of occupational health services to our business customers. Occupational health services may include absence management, medical counselling, rehab support and health promotion support. If our business customers, your employer or client, have contracted us to provide our services, our subcontractors, where they provide advice to you on your wellbeing, become data controllers under the Patient Data Act. They have their own privacy policy for this.

03. Personal data that we collect and process

We sometimes process your personal data for our own purposes, to make sure our product works well and to give you a better user experience, we do so under our own personal data responsibility. Here is the type of information we collect and use:

User data: Your name, who you work for and how we can contact you, such as your email address.
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Technical data: Information about your device and how you use our product, such as your IP address, how you log in, the type of computer or phone you use and settings such as language and cookies.

Usage data: How you use our product, such as what features you use and how long you are active.

04. How we receive your personal data

When an account is created for you in the Product, we receive Usage Data from our Business Customers. We may also automatically collect and process Technical and Usage Data from you or generated by you in connection with your use.

05. Purpose with processing your personal data

In order for us to use your personal data lawfully, there must be a good reason for doing so. We carry out the personal data processing operations described below for the purposes and on the legal grounds set out below. If you have any questions about our processing of personal data, please contact us.

Support cases: If you need help with our product, we will use your data to identify you and manage your case. Sometimes we also need technical information to solve the problem. We do this because we want to give you good support and answer your questions.

Product improvements: We collect and analyse your Technical Data and Usage Data to make our product and related services and products even better. We look at patterns and statistics to see what we can improve. We use anonymised data so that you cannot be identified.

Work environment & health statistics: We compile data on work environment experience and health to help employers review the wellbeing and safety of their staff. We only use anonymised data that cannot be linked to individuals.We use anonymised statistics to gain a better understanding of health trends across industries and the wider labour market. This information is valuable to us and our Corporate Clients as it helps us gain an overall picture of health status. We share this comprehensive overview with our Corporate Clients, partners and may also publish it on our website.

Prevention of misuse and to prevent crime: Your Personal Data may also be used to prevent misuse of the Product or to prevent, deter or investigate crime. We also process your Personal Data to fulfil our legal obligations under law, judgments or other official decisions, for example requirements regarding accounting. We carry out such processing on the basis of our need to fulfil our legal obligations and our legitimate interest in preventing misuse of the Product.

Information and communication: From time to time we will send you information about our Product and important events. This is to keep you updated and informed about what is happening.

06. How we may share your data with other parties

We do not share your personal data with other parties, except in the ways described here in our privacy policy.

Sharing with suppliers: Sometimes we use suppliers to manage certain aspects of our business, including our product. This may mean that we share your personal data with these suppliers, but only to enable them to perform their services for us, such as storing data, ensuring the security and availability of the Product or providing IT services.

When we share your personal data with suppliers, we make sure that they comply with our data protection policies and laws. We are always responsible for how your data is processed, even when it is done by a supplier for us.

Sharing with authorities: Sometimes we may be required to share your personal data with various authorities and public actors by law, such as the Swedish Tax Agency, the Swedish Social Insurance Agency, or the Swedish Police.

07. Retaining of data

We take a variety of security measures to protect your personal data. We use advanced encryption methods to protect sensitive data transmitted over the internet. The computers/servers used to store personally identifiable information are stored in a secure environment within Sweden.

We will retain your Personal Data for as long as necessary to fulfil legal requirements and the purpose for which it was collected.

If there are other purposes that do not conflict with the original purpose, we may also retain them.

Your User Data is stored for as long as you have an active account with us. If our clients terminate the contract with us and your account is deactivated, we will delete your Personal Data within six months.

We will delete data that is no longer needed for the original purpose or if there is no longer a legal basis for processing it.

08. Profiling your data

The Wellbefy app and web platform use your personal data to create a profile of you. This profiling is mainly based on your age, gender and your work and health data. Based on this data, the platform can suggest first steps for preventive measures to improve your health. The profiling is part of the product, and the responsibility for it lies with us.

09. Your legal rights

You have certain rights under data protection law (GDPR) in relation to your personal data. Here are some important things to know about your rights:

Right to information and rectification: You can request to know what personal data we hold about you and correct any inaccuracies.

Right to erasure: We will erase your personal data when it is no longer needed or if you request it, provided that it does not contravene any laws or regulations.

Right to withdraw consent: If you have given us your consent to process your personal data, you can withdraw that consent at any time.

Right to restrict processing: You can request that we restrict our processing of your personal data in certain circumstances, for example if you believe the data is inaccurate.

Right to data portability: You have the right to receive your personal data in a structured and readable format and to transmit it to another controller.

How to exercise your rights: If you wish to exercise any of your rights, please contact us. We will process your request as quickly as possible and inform you of the reasons if we cannot fulfil your request.

10. Contact Details

You are always welcome to contact us with questions about our personal data processing or to exercise your rights! The easiest way to reach us is through the following email address: kontakt@wellbefy.se