With Greenhabit, you develop skills to maintain healthy habits. This improves the quality of life. We are committed to protect the privacy of visitors to www.greenhabit.nl and participants of the Greenhabit game available via Google Playstore and IOS App Store. In this privacy policy we inform you about the data we collect from you, how we use this data and what steps we take to protect the data. By using the website and the Greenhabit game, we may collect, use, disclose and retain your personal information as described in this privacy policy.
Applicable to
This privacy policy applies to all areas of the game, the website and the Greenhabit Dashboard. Greenhabit wants to help people improve their lifestyle, vitality and happiness. To achieve this goal, data is collected from visitors of the website and data is collected about the personal lifestyle, measurement data and preferences of the participants in the game. The game and website are managed by Greenhabit BV. registered in the Chamber of Commerce register under number: 70837872. Because the privacy of our website visitors and participants is important to Greenhabit, we have registered a Data Protection Officer (DPO) with the Data Protection Authority under number FG009140 accessible via e-mail address privacy@greenhabit.nl. The DPO’s role is performed by an external independent party.
All data are stored and processed by Greenhabit BV on servers stationed within the European Economic Area (EEA).
When do we collect personal data?
Greenhabit BV acts for the processing of personal data in accordance with the General Data Protection Regulation (GDPR).
When you visit our website, we do not collect any (personal) data other than the functional cookies sent to us by your computer, mobile device or other device you have accessed. We process your personal data only when you use our services and/or because you provide this data to us yourself via a registration form on the website.
We collect the following personal data:
- Website data: When you visit our website, we use only functional cookies that are necessary for the proper functioning of the website. Therefore, we do not collect personal data based on your visit to our website.
- Registering for Program: When registering to participate in a project, we collect the information you provide: (Name, E-mail address, phone number and desired start date.
- Order Greenhabit game: When ordering and registering in the game, we collect the information provided by you: (Company) name, E-mail address, address, zip code, city, country, name of employee, phone number, VAT number and payment information.
- Data in the Greenhabit game: When using the Greenhabit game, we collect the data provided by you: first and last name, address, zip code, E-mail address, mobile phone number, height and weight for BMI determination, waist circumference, glucose value, HbA1c, blood pressure, cholesterol and triglycerides. The data on challenge results and uploaded photos, information about your lifestyle based on your answers to quality of life questions and preferences regarding the 5 elements: nutrition, exercise, relaxation, positivity and your social environment. The personal data is shown in the “insights” menu to show the development of personal measurements but also your energy, happiness, positivity, social and work-life balance. This will give you a picture of your progress. You decide whether to register a personal measurement value in Greenhabit. The data will NOT be shared with others and will remain Private to you.
- Device Data: We collect information about your mobile device: model, name and identifiers, device settings, and location in the Game when Feedback ( “!” button) is given in the game. If a participant asks a question via the ‘!’ button at the top right of the App screen, we collect device data from the participant.
How do we use your personal data?
We base the processing of your personal data on the following principles:
- To fulfill agreements with you (for example, sending the newsletter, responding to an inquiry, delivery of the Greenhabit package or reward and making an invoice);
- On the basis of permission (once you have given permission, you can withdraw it at any time);
- For compliance with a legal obligation.
- Justified interest to better serve participants by further improving the game.
Data will only be provided to third parties if this is necessary for the execution of our agreement with you or to comply with a legal obligation. A processing agreement is in place with third parties in which the arrangements are made regarding the processing of personal data. Your data is processed in the Greenhabit dashboard which converts individual data to company averages. This means that your individual personal data is not visible in the dashboard. The company averages are only calculated when at least 15 participants from a company participate so that privacy is guaranteed. The data is translated into the following 6 vitality domains: Energy, happiness, work-life balance, positivity, social environment and BMI. For each vitality aspect, the dashboard shows the status per week in the form of “high, medium, low”.
In addition, we show the employee’s appreciation of the employer’s attention to a “vital work environment”. This gives the employer an idea of whether he pays sufficient attention to creating a vital working environment for his employees. This offers the employer the opportunity to improve on the aspects on which he is less well assessed. Again, this employee rating is only displayed with a minimum of 15 participants in the group to ensure privacy.
The individual data of the participant participating in Greenhabit as a buddy is not shown and included in the calculations in the Greenhabit dashboard.
Adjusting personal data, unsubscribing and deleting
All your processed personal data are visible in the game. If you have made a mistake when entering measurement values, you can correct them by going to the relevant measurement in the travel report and adjusting it.
Questions regarding the processing of personal data can be emailed to privacy@greenhabit.nl. If you want to terminate the processing of personal data, in the Greenhabit game at “settings” under menu heading: “Account”, you can choose Delete Account. This will delete your account on your mobile device including all personal data. Also, the anonymization of your personal data in the database linked to the game is stopped. This will remove all photos and data that can be traced back to you. By pressing the “Delete Account” button, Greenhabit cannot restore your account and it is permanently deleted, nor can you continue in Greenhabit at a later time with your data preserved.
Authorizations
As a Greenhabit participant, depending on your choices, you may see the following data:
- Your weight, your BMI, your personal measurements such as waist circumference, glucose value, HbA1c, blood pressure, cholesterol and triglycerides. The calculated level of energy, happiness, positivity, social environment and work-life balance.
- Your attention for the 5 elements: nutrition, exercise, positive thinking, relaxation and social environment.
- Own content placed in the game but also the content of “friends” who have chosen to share it. If you choose not to share photos they will remain private.
- Depending on your settings under the privacy tab in the game, other participants may see your photos.
Greenhabit BV can see the following data:
- List participants by name (management accounts), organizational data.
- Average BMI, energy, happiness, positivity, social and work-life balance at the organizational level for a group size greater than 15 participants.
- Number of companies total.
- Number of participants total.
- Average scores Organization.
- Number of minutes played, sessions and challenges per participant.
Participating Organization may see following information:
- If more than 15 participants are active in the dashboard. Average score of participants (group larger than 15) regarding attention to the 5 elements: nutrition, exercise, positive thinking, relaxation and social environment within the organization translated to “high, medium, low.”
- Employee appreciation for employer’s attention to a vital work environment when group size exceeds 15 participants.
- Term of the licenses.
Data protection
To protect your personal data, we have implemented various security measures. For example, we have an additional security (MFA) on the Dashboard using a code from an Authentication App in addition to a username and password. The game is secured by a username, password and an additional SMS code sent to the phone number you provided. Communication between the game and our Servers is encrypted and not readable by third parties. We work in accordance with the ISO 27001 standard for information security to protect your personal data. Personal data can be accessed only by a limited number of persons who have special access rights to it and are obliged to maintain data confidentiality.
Greenhabit does not use automated decision making based on profiling.
Retention periods
We do not store your data longer than necessary for the realization of the purposes for which they were collected and processed. As a participant, you yourself are able at any time to stop the anonymization of personal data in the database and delete your account with all your photos and data that can be traced back to you personally.
The data processed in the Greenhabit game will be kept for 4 years after your last use of the game. With this we enable you to use the Greenhabit game again at a later time while retaining your own data. Also, after your training program, you can look back at a later time in your travel log where all content and challenges are saved.
The foregoing retention period does not apply if there is a legal obligation, or in case we need the data longer for our services or a dispute.
Improvement of the Game
Greenhabit uses your data in anonymized form for game improvement. We anonymize your data by removing all data that can be traced back to you personally. Therefore, when participating in Greenhabit, data is anonymized. When you decide to delete the Account (via settings/account) the anonymizing of data is stopped and all photos and data that can be traced back to you personally are deleted. Anonymized data is used only for game improvement. Greenhabit does not share anonymized data with other parties for commercial applications.
How do we store your data?
Greenhabit BV securely stores your data processed via the website at “Your Hosting BV” on servers in Europe, which means that they fall under the provisions of the GDPR.
Greenhabit BV securely stores your data processed through the game at “Linode LLC” on servers in Europe, which means that they fall under the provisions of the GDPR. Linode LLC is ISO 27001 certified.
To secure your data, connections through the website and App are encrypted using an SSL certificate.
Links to third parties
For your convenience and provision of information, our website and the Greenhabit game may contain links to third-party websites, which may have different terms for processing your personal data. We are not liable for the processing of your personal data via third party websites. We advise you to read the privacy policy of the relevant website before providing personal information. We do not sell or transfer your personal information to third parties. Personal data are only processed by parties with whom Greenhabit has a processing agreement and who comply with the GDPR. Our partners support the performance of our services through website, mobile applications and data storage. Our partners agree to keep your personal information secure and confidential. Such agreement is subject to applicable data protection law and this Privacy Policy. Data will only be provided to third parties if this is necessary for the execution of our agreement with you or to comply with a legal obligation.
For your convenience, we offer the ability to synchronize the steps recorded by the mymonX smartwatch with the steps challenge in Greenhabit. For this, you need to give your own approval in mymonX to share the data with your Greenhabit account. From Greenhabit, NO data is shared with mymonX. For processing the steps data, Greenhabit has entered into a Data Transfer Agreement (DTA) with Aitis-mymonX.
Greenhabit BV has concluded a processing agreement with:
Grendel Games BV
They are the developer of the Greenhabit game and web-based dashboard. Your data is processed and secured in accordance with the agreements laid down in the processing agreement in accordance with the GDPR. Grendel Games BV handles the processing of your data on servers of Linode LLC in Europe with which a processing agreement has been concluded and which comply with the GDPR.
Your Hosting BV
They are the hosting provider for storage and processing of your data for the Greenhabit website. Your data is processed and secured in accordance with the agreements in the processing agreement in accordance with the GDPR.
Seacon Logistics
They are the logistics provider that makes sure the Greenhabit package is delivered. Your data is processed and secured in accordance with the agreements in the processing agreement in accordance with the GDPR.
Changes to this Privacy Policy
This privacy statement can be amended to make improvements. The most recent version will be available on our website www.greenhabit.nl. The revised version of the privacy policy is effective from the date of publication on the website.
Secure personal data and data leak
Greenhabit BV takes the protection of your data seriously and takes appropriate measures to prevent abuse, loss, unauthorized access, unwanted disclosure and unauthorized modification. If you feel that data is nevertheless not properly secured or there are indications of misuse, please contact our Data Protection Officer (FG) at privacy@greenhabit.nl. The DPO role is filled by an external independent party.
You have the right to file a complaint and can do so through the DPO or the Personal Data Authority. For this, the link: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons
In the case of a data Breach, we will inform the Personal Data Authority whether there is lost data or theft of data, what data is involved and when the data breach occurred.
Contact us at:
06 – 42676132
privacy@greenhabit.nl
Hulterman 50, 5721 MD Asten
Privacy Policy version: gw-v.7EN
[1] EER: these are all the countries of the EU plus Liechtenstein, Iceland and Norway