Privacy Policy

Updated November 01, 2019

This privacy notice is for users who use the SureMission platform.

The SureMission “platform” consists of our website www.suremission.com (our “Website”, the SureMission Web and mobile apps ( “Apps”), cloud services, and any other services offered via the Website, Apps or Cloud Services.

In this notice, we will tell you how we process personal data and any other data you, or your community users store on the SureMission platform.

SureMission is responsible for providing and managing the SureMission platform.

For the purposes of branding and providing the SureMission platform service to your community users, SureMission and you, the SureMission Customer, act as joint Data Controllers, which means SureMission and you decide how the data is processed. SureMission acts as Data Processor, which means SureMission is responsible for processing the data. Suremission and Suremission's customers are jointly referred to as (Our, Us) in this privacy policy.

Please read this privacy notice carefully to understand the types of information we collect, how we use that information, the circumstances under which we will share it with third parties, and user's rights in relation to the personal data you provided on the SureMission platform.

Contact details for SureMission is listed at the bottom of this notice.

How we collect personal data

Data is collected in a few ways:

  • Data that given directly by users when you they use SureMission platform, delivered by our customers with our csutomer's branding to their users. This data includes data given by users when they:
    • fill in forms on our Website or Apps, or correspond with us by phone, email or otherwise;
    • register to use our Services, subscribe to our newsletter, promotional emails or other marketing materials;
    • use the Services;
    • report a problem with our Services; or
    • complete any surveys we ask a user to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).
  • Data given about a user (by a family member, by a healthcare team, or support organisation)
  • Data we collect when a user uses the SureMission platform.

Legal Basis

Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of personal data in this policy notice. These are the principal grounds that justify our use of information:

  • Consent:where a user has consented to our use of their information (they are providing explicit, informed, freely given consent, in relation to any such use and may withdraw consent in the circumstance detailed below by notifying us);
  • Contract performance:where information is necessary to enter into or perform our contract with the user;
  • Legal obligation:where we need to use a user's information to comply with our legal obligations;
  • Legitimate interests:where we use a user's information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to the user's data protection rights; and
  • Legal claims:where a user's information is necessary for us to defend, prosecute or make a claim against you or a third party.

We use information held about a user(and information about others that you have provided us with) in the following ways:

Information we may collect and use

Here is a list of categories of personal data that is collected and used. Some of these are optional.

Contact and personal information (some optional personal information),

Including profile picture, name, gender, date of birth, email address, phone number, address, location, etc.

Uses of that Information:

  • To provide the user with access to our Website, Apps and any other information which the user requests from us, and to use our Services.
  • For marketing products and services that we believe will be of interest to the user. (Email address, Name).
  • To administer our Services and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.

Use Justification:

  • Contract performance
  • Legitimate interest (for marketing our own similar products and services and any re-engagement campaigns) (Email address, Name).
  • Legitimate interest (to administer and improve our Services).
  • Consent (for marketing unrelated products or services or products or services of third parties) (Email address, Name).

Account Access Information

Including Name, Email, Date of Birth, Password

Uses of that Information:

  • To provide the user with access to our Website, Apps and any other information which the user requests from us, and to use our Services.

Use Justification:

  • Contract performance
  • Legitimate interest (to administer and improve our Services).

User passwords are stored on SureMission’s servers in encrypted form. We do not disclose user account details. It is the user's responsibility to keep the user's password secure.

Sensitive information between browser and our Website is transferred in encrypted form using Secure Socket Layer (“SSL”). When transmitting sensitive information, users should always make sure that your browser can validate the SureMission certificate.

Health Information (Optional)

Including: General Health Information, Allergies, Care Planning Notes & Documents, Medicine Details, Duties Required, Hobbies & Interests

Processing of Health Data falls under the provision of ‘Processing of special categories of personal data’, GDPR Art.9(2)(h) & GDPR Art.9(2)(i) of the General Data Protection Rules Act (GDPR), and we ensure that appropriate safeguards, mentioned therein, are in place.

Uses of that Information:

  • To provide users with Healthcare management services available on the SureMission Platform.
  • To administer our Services and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.

 Use Justification:

  • Consent (we require user consent to process your sensitive personal data, which is required in order to provide the Services).
  • Contract performance.
  • Legitimate interest (to administer and improve our Services).
  • Legitimate interest (to tailor our services appropriately). No marketing of additional service offers will be conducted without user consent.

Scheduling and Appointment Information (Optional)

Including healthcare professional appointments, other appointments, alerts and reminders for appointment, medicines, etc.

Uses of that Information:

  • To provide users with Healthcare management services available on the SureMission Platform.

Use Justification:

  • Contract performance

Work experience & training record (for healthcare professionals, volunteers) (optional)

Professional users of the platform are able to record and track work experience and training of themselves or their team (if managing a team)

Uses of that Information:

  • To provide user with Healthcare and recruitment services available on the SureMission Platform.
  • To administer our Services and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.

Use Justification:

  • Contract performance
  • Legitimate interest (to administer and improve our Services).

Notes (optional)

Including notes that users choose to create and store on the SureMission platform.

Uses of that Information:

  • To provide user with Healthcare management services available on the SureMission Platform.

Use Justification:

  • Contract performance
  • Legitimate interest (to administer and improve our Services).

Community posts and information (optional)

Includes any posts, comments, likes/dislikes, information, links, photos, etc that users post on community pages, or the community pages of others.

Uses of that Information:

  • To provide users with Community available on the SureMission Platform.

Use Justification:

  • Contract performance
  • Legitimate interest (to administer and improve our Services).

Other personal information (private, group chat/messaging)

Includes private and group conversation messages.

Uses of that Information:

  • To provide users with communication services available on the SureMission Platform.

Use Justification:

  • Contract performance.
  • Legitimate interest (to administer and improve our Services).

Users are responsible for all content that they post to the Community on the SureMission platform, including content shared in private or group chat messaging. Users must not post offensive content or content from third parties for which they do not have the rights, licenses, consents, or releases or content that will infringe, misappropriate, or violate a third party’s patent, copyright, trademark, trade secret, moral rights, or other intellectual property rights, or rights of publicity or privacy, or result in the violation of any applicable law or regulation.

Other information (Analytics)

With regards to user visits to our Website or Apps, we may automatically collect the following information; however, this information cannot be used to identify a user:

  • device-specific information, such as user hardware model, operating system version, unique device identifiers, and mobile network information;
  • technical information about the user's computer, including where available, the user's IP address, operating system and browser type, for system administration and analytical purposes;
  • details of user visits to our Website and App, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website and App (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs); and
  • information showing us from which app store the user downloaded our App.

Using the SureMission platform or services on behalf of a third party.

If a user is using the SureMission platform or services on behalf of a third party, the user must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us. For the avoidance of any doubt, any reference in this privacy policy to user data shall include data about other individuals that a user has provided us.

Links to third-party websites

Our Website or Apps may contain links to third-party websites. For example, someone may post a link to a third-party website or service in the Community section or chat feature on the SureMission platform. If a user follows a link to any third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or their processing of any personal information a user may submit to them. Accordingly, SureMission cannot guarantee that the controller of that website will respect user privacy in the same manner as SureMission does. Please check these policies before submitting any personal information to such third-party websites.

How we use Cookies

Cookies allow web applications to respond to a user as an individual. The web application can tailor its operations to a user's needs, likes and dislikes by gathering and remembering information about user preferences.

Cookies are small, usually randomly encoded, text files that help you navigate through a website. They are generated on the sites that you visit, as well as by third-parties that websites work with, to manage key elements of their business-user functionality. In most cases, they do not involve or use personal information in any way.

Cookies are used extensively online and have become part of the fabric and make-up of what has made the internet work effectively for consumers and businesses. Without cookies, many areas of functionality (for example, user logins, shopping baskets and other customization features) would not work as expected.

Cookie types

Session cookies

Session cookies are temporary cookies that are not stored on a user's computer or mobile device. They are used as part of the login, authentication and session management flows. Certain session cookies are also used to understand, for example, if a user interacting with our website is a new visitor or a visitor returning as part of the same browsing session. These session cookies are erased when a user closes their browser, or after extended inactivity.

Persistent cookies

Persistent cookies are those placed on a user's computer or mobile device for a pre-determined length of time when a user visits this site. They are used on both the platform and our websites, including, for example, to understand (through Google Analytics) what areas of our websites and platform are most popular, and how customers and users engage with them.

Cookie management

Users have the ability to accept or decline the use of cookies. Most web browsers automatically accept cookies, but a user can usually modify your browser setting to decline all cookies if preferred. Alternatively, many web browsers can be configured to notify the user each time a cookie is tendered, and permit the user to accept or decline them on an individual basis or on a site-by-site basis. If the user chooses to decline cookies from SureMission’s website or Apps, the User may experience some unexpected behaviours or impact to the use of the hosted software

User rights

Users have rights regarding their personal data. If a User have any questions please contact your service provider or SureMission.

Right to information about the processing of a User's personal details

The aim of this privacy notice 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 if it could affect your rights, freedoms or interests.

Right to data portability

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 us or your service provider (Healthcare team, or support organisation) first.

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

Contact details for SureMission can be found at the end of this page.

Third parties

We use third-party sub-processors to host the SureMission platform, capture analytics, and communicate with a user.

Microsoft Azure

We use Microsoft Azure to host the platform, services, and databases.

Location of hosting and processing: EU

Microsoft Azure: privacy notice

Sendgrid

We use Sendgrid as an email engine, and to manage email campaigns.

Sendgrid: privacy notice

Google Analytics

We use Google Analytics to generate visitor analytics to our website and provide us with anonymised data regarding website visitor numbers and behaviour.

Google Analytics: privacy notice

Data Security and Storage

We are committed to ensuring that user 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.

All SureMission employees are contractually and ethically bound to respect the confidentiality of any personal data held by SureMission.

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page and notified to you by email. We, therefore, encourage you to review it from time to time to stay informed of how we are processing your information.

Contact

SureMission:

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to hello@suremission.com Subject: Data Protection

SureMission’s Data Protection Officer is Owen O’Doherty.


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