Privacy Notice

Effective date: 30 January 2023

This privacy notice is for people who use this SilverCloud® by Amwell 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, Amwell is the “data controller”, which means we decide how and why your data is processed. Contact details for  Amwell are listed at the bottom of this notice.

There is a separate privacy statement for people who use the SilverCloud® by Amwell platform and programmes.

How we collect your personal data

Your data is collected by us in a few ways:

• Data you give directly
• Data we collect automatically when you use the website
• Data about you we get from third parties

What personal data we collect and use

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 preferences, location, use of our website and emails

IP address, unique identifiers, browser type and version, time zone and language, location, pages viewed

Events

Event registration details include first name, surname, email and job title. We may also video record the events for future uses.

Data we do not collect

Children's data

SilverCloud® by Amwell website and marketing activities are 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® by Amwell 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.

How and why we use your personal data

SilverCloud® by Amwell processes your data for specific purposes and where there is a legal basis.

Enquiries

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

Events

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

Marketing

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

Understanding usage and improving services

SilverCloud® by Amwell records data and uses analytics tools to help analyse how users use the site.

Legal basis: legitimate interests

Call recording

With your consent, we may record sales and customer success calls, to reduce the need for note-taking, allow for better follow up and for coaching of employees. We will link call recordings and transcripts with your business contact details.

Legal basis: consent

Legal basis

This explains the legal bases mentioned above

Consent

We get your permission before processing your personal data, in some cases.

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:

• Communicating in response to enquiries
• Communicating relevant information to existing or potential business customers
• Understanding the interests and needs of our website users
• Maintaining the performance and security of our website and other services

These interests may be overridden by your rights and interests.

Your choices

Cookies

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.

Marketing

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.

Your Rights

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® by Amwell first.

Contact details for the Data Protection Commission can be found at https://www.dataprotection.ie

Right to withdraw consent: where we process your data on the basis of consent, you have a right to withdraw your consent.

You may have also heard about the following rights, however we believe they are not relevant to SilverCloud® by Amwell use of your data.

Rights in relation to automated decision making: we do not use automated decision making with legal or other significant effects.

Third parties

We use third parties to host our website, analyse usage and communicate with you

Hosting

Analytics

Marketing & Sales

International transfers

We may transfer, process or store personal data about you in countries other than your own, which may not have the same data protection laws as your country. When we transfer your personal data to other countries, we will protect that information as described in this privacy notice. Whenever we transfer personal data outside of the EEA, the UK or Switzerland, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. This includes the use of EU Controller-to-Processor Standard Contractual Clauses (SCCs).

Links to other websites

You should also be aware that where you link to another website from the SilverCloud® by Amwell website, that SilverCloud® by Amwell has no control over that other website. Accordingly, SilverCloud® by Amwell cannot guarantee that the controller of that website will respect your privacy in the same manner as SilverCloud® by Amwell.

Data security

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® by Amwell maintains ISO 27001:2013 certification.

Retention of Personal Data

Personal Data shall be retained only in accordance with the Data Retention requirements of SilverCloud® Privacy Policy.

Privacy notice changes

We will revise this privacy notice when necessary and we encourage you to check back in future for changes.

• 25 May 2018 update for GDPR
• 16 Aug 2018 update DPO details; include HubSpot, SalesBetty and Cognism as third parties
• 10 Dec 2018 update Cyber Essentials certification
• 08 June 2020 update Marketing suppliers and and activities
• 10 Nov 2020 update Cyber Essentials certification
• 13 Nov 2020 update ISO 27001 certification
• 19 Mar 2021 update third parties, rights
• 7 Feb 2021 add third parties Highspot and Reachmail
• 2 Sep 2022 update ISO 27001 certification
• 30 Jan 2023 remove third parties Reachmail, Zapier; add third party Gong (call recording); minor branding changes.

Contact

If you wish to contact SilverCloud® by Amwell regarding our use of your Personal Data or to exercise your rights, please contact us at:

SilverCloud® by Amwell
One Stephen Street Upper
Dublin 8
Ireland

dataprotection@silvercloudhealth.com

SilverCloud® Data Protection Officer (DPO) is BH Consulting:

SilverCloud® Data Protection Officer
BH Consulting
The LINC Centre
Blanchardstown Road North
Dublin 15
Ireland

dataprotection@silvercloudhealth.com