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Privacy Notice
Effective date: 20 July, 2021
Your Privacy
This privacy notice is for people who use SilverCloud. We have a separate notice for our marketing website and emails.
Who we are
We are SilverCloud and we make the SilverCloud platform and programs. Healthcare services and other organizations offer SilverCloud to people. To keep things simple, we say “your healthcare service” even if it is a school or company. This notice explains how we handle your personal data for your healthcare service. We also use some of your data to learn how SilverCloud is used and to improve it.
Coaching
Parts marked “Coaching” apply if you are working with a coach. These parts do not apply if you are using SilverCloud by yourself.
Contact us
If you want to ask us about your data, you can write to us at dataprotection@silvercloudhealth.com or to our mailing address. See the contact details section at the bottom.
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Personal data – what is it?
Your personal data means any information that could be used to identify you, like your name or email address. It also means information about you, and SilverCloud is used for quite sensitive information. It does not mean anonymous data or statistics.
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How we get your data
We collect your data when:
- you enter it into SilverCloud
- it is created when you use the program
Coaching
- your coach gives it
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What personal data we use
Here is a list of the kinds of data we use.
- Contact details
- Health (PHI)
- Profile
- Feedback
- Usage
The data we collect depends on what your healthcare service asks for and what you choose to give.
Contact
Your name and email address, for notifications.
If needed:
- ZIP code
- Mailing address
- Phone number
Health (PHI)
- Your healthcare service
- Your SilverCloud program
- Answers you give to questionnaires and results
- Entries in your journal, mood tracker or other tools
Coaching
- Messages to and from your coach
If needed, or if you choose to give it:
- Date of birth
- Physician name, address and phone number
- National or local ID number
- Data about disability, health condition, or treatment
Profile
For your SilverCloud account:
- Login details: email address or username and password
- Language
- Time zone
- Other preferences
If needed, or if you choose to give it:
- Age
- Gender
- Ethnicity
- Education
- Interests
- Likes or dislikes
- Profile image
Feedback
- Feedback at the end of each module
- Surveys
Usage
- Your IP address, browser type, and version
- When you log in or out
- Pages and sections viewed
- Actions you take on SilverCloud
- Emails sent to you
- Server or other errors that affect you
Children’s Data
Most SilverCloud programs are meant for people age 16 or over.
SilverCloud programs for adolescents are intended for children and young people age 15 or over. We do not knowingly collect personal data from children under 13. If you think a child under 13 has given us personal data, please contact us
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What we do with your data
Here we tell you what we do with your data for certain purposes.
SilverCloud program
We use your data to make the SilverCloud program work. This includes:
- Logging in
- Showing you pages
- Keeping track of what you read and do on SilverCloud
- Scoring questionnaires
- Saving your preferences
- Sending notifications
We may use profiling or machine learning.
Coaching
Coaching
We use your data for coaching if you are working with a coach. This includes:
- Inviting clients and coaches
- Checking your progress and scores from questionnaires
Safety
We use your data to protect your safety or someone else’s safety if we think we need to.
Technical support
We use your data to help you use SilverCloud if you contact us by email, telephone or on the platform.
Learn how people use SilverCloud
We use your data to learn how people use SilverCloud and to find out if it helps them. This helps us make SilverCloud better.
We change your data into statistics or data that does not identify you. We use as little data as we can. We may use profiling or machine learning.
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Our responsibilities
We only use your data when it is allowed under at least one of these legal grounds.
Contract – We use your data when we need it to provide you with services under a contract
Consent – We use your data if you tell us we can. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
Legitimate interests – We use your data when we have a good reason and where we take steps to protect your privacy. This includes:
- Technical support
- Learning how people use SilverCloud and finding out if it helps them
- Understanding trends
- Planning improvements
- Keeping SilverCloud working, safe and secure
- Meeting our responsibilities under the law and customer agreements
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Your rights
When it comes to your data, you have certain rights.
Be informed
This notice tells you how we handle your data. You can write to us if you have any questions.
Get access to it
You have the right to know if we hold your data, what kind of data, and to get a copy of all data about you.
Correct or change it
You have the right to correct any inaccurate data. You can ask us to correct data about you that you think is wrong or missing. Ask us how to do this by email to dataprotection@silvercloudhealth.com
We may say “no” to your request, but we will tell you why in writing within 60 days.
Erase or remove it
You have the right to remove data if we do not need to keep it.
You can ask us to remove content you have posted. Ask us how to do this by email to dataprotection@silvercloudhealth.com
We may say “no” to part of your request if a law requires us to keep that information.
Restrict or stop processing it
In certain cases, you can ask us to stop using your data and only store it. For instance, if you object to how we use it or think we are using it against the law. Ask us how to do this by email to dataprotection@silvercloudhealth.com.
Move, copy or transfer it
We will give you data we get from you in a common computer format.
Object to it being processed or used
You can object to how we process your data if it could affect your rights or interests.
Know if a decision was made by a computer rather than a person
We do not let the program make big decisions about you on its own.
Make a complaint
You can complain if you think we did not respect your rights. You can complain to your healthcare service. You can contact us by email to dataprotection@silvercloudhealth.com or by mail.
You can also make a complaint to the authorities:
Department of Health and Human Services Office for Civil Rights 200 Independence Avenue, S.W., Room 509F HHH Bldg., Washington, D.C. 20201
https://www.hhs.gov/hipaa/filing-a-complaint/
We will not treat you badly for making a complaint.
Learn more about your rights
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Who can see your data
Sharing
We will only share your data with other organizations or people for a few reasons. Here is a list of them.
Service providers
We use service providers to help us run SilverCloud. Your data will be put on their services.
Legal
We will share your data if we get a legal request that we think we have to obey, or to help fight crime, or if there is a court case.
Safety
We will share your data with your doctors, emergency services or authorities to protect your safety or someone else’s safety if we think we need to.
We may share reports of side-effects of medicine or medical devices.
SilverCloud companies
We may share your data with our other SilverCloud companies to help us run SilverCloud, and we will follow the rules of this notice.
Learn how people use SilverCloud
We may share anonymous data or statistics with consultants or researchers that we work with.
In general, we take care that anonymous data or statistics do not identify you, and we can share them any way we like.
Service providers
We use service providers to help us run SilverCloud. They must agree to protect your data.
US version
Name
Details
Location
Armor
Web and data hosting
US (Texas)
Amazon Web Services
Backups and email
US (US-East)
Zendesk
Technical support
US / global
International transfers
We store your data in the place we have agreed with your healthcare service. This is usually in the country where they are based. In the EU we can store data in other EU countries.
We always follow the law and the agreement with your healthcare service when moving data to other countries.
For technical support we may need to share some data with SilverCloud staff in other countries.
Links to other websites
If you follow a link to a website we do not control, we are not responsible for what other companies do with your data on their website.
Data Security
We do our very best to keep your data private and secure. We protect your data from being stolen from buildings or hacked over the Internet.
We will let you or your healthcare service know promptly if a breach happens.
We also have written rules for how we protect data. SilverCloud staff know and agree they must keep your data private and secure.
SilverCloud is tested by security experts every year.
SOC 2 + HITRUST Type 2 assessment (article)
We check that services providers can keep your data secure.
Cookies
We use cookies because we need to let SilverCloud know that you are logged in, to keep your account secure, and to store preferences like language. Our cookies do not collect any information for marketing or tracking where you have been on the web.
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How long we keep your data
We have rules for how long we can keep your data.
- We keep your data while your account is open and for 3 months after it is closed.
- We keep technical support queries for 5 years.
- We keep anonymous data and statistics as long as we like.
Coaching
- If SilverCloud is providing coaching, we keep coaching records for 8 years.
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Privacy notice changes
We will update this notice when needed. You should check back in future for changes.
20 July, 2021:
First version of simple privacy notice.
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Summary
Why and how we process your data in SilverCloud and your rights.
Controller
- Your healthcare service
- SilverCloud
- when we act directly as a well-being or healthcare service
- for data we collect for our own use, like feedback and statistics
How we use the information
(processing activities)- To provide SilverCloud
- Technical support
- Learn how people use SilverCloud
Does this contain sensitive (special category) data such as health information?
Yes
Who are recipients of this data?
Service providers that help us
Other SilverCloud companies, if needed
Government or law enforcement, if required
Is your data sent outside your country?
No, unless you get in touch with our technical support.
How long the data is kept
- We keep data while your account is open and for 3 months after it is closed.
- We keep technical support queries for 5 years.
- We keep anonymous data and statistics as long as we like.
Our legal basis for getting and using the data
- Contract
- Consent
- Legitimate interests
Your rights
- Be informed
- Get access to it
- Correct or change it
- Erase or remove it
- Restrict or stop processing it
- Move, copy or transfer it
- Object to it being processed or used
- Know if a decision was made by a computer rather than a person
How can you withdraw your consent?
You can ask us by email
Are decisions made only by computers?
(solely automated decision making)No
Where does the data come from?
- you enter it into SilverCloud
- it is created when you use the program
Coaching
- your coach gives it
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Contact Details
SilverCloud Health Data Protection Officer
BH Consulting
The LINC Center
Blanchardstown Road North
Dublin 15
IrelandSilverCloud Health Inc
50 Milk Street
16th Floor
Boston, MA 02109
United StatesSilverCloud Health UK Ltd
Suite 1350
Kemp House
152 City Road
London, EC1V 2NX
United KingdomICO Reg. No. ZA861048
SilverCloud Health Ltd
One Stephen Street Upper
Dublin 8
D08 DR9P
Ireland