PRIVACY NOTICE



Last updated December 22, 2022



This privacy notice for University College Cork ('Company', 'we', 'us', or 'our'), describes how and


why we might collect, store, use, and/or share ('process') your information when you use our


services ('Services'), such as when you:



▪ Download and use our mobile application (Digital Mental Health Hub), or any other



application of ours that links to this privacy notice



▪ Engage with us in other related ways, including any sales, marketing, or events



Questions or concerns? Reading this privacy notice will help you understand your privacy rights


and choices. If you do not agree with our policies and practices, please do not use our Services. If


you still have any questions or concerns, please contact us at 121125811@umail.ucc.ie.



SUMMARY OF KEY POINTS



This summary provides key points from our privacy notice, but you can find out more details


about any of these topics by using our table of contents below to find the section you are


looking for.



What personal information do we process? When you visit, use, or navigate our Services, we


may process personal information depending on how you interact with University College Cork and


the Services, the choices you make, and the products and features you use.



Do we process any sensitive personal information? We may process sensitive personal


information when necessary with your consent or as otherwise permitted by applicable law.



Do we receive any information from third parties? We may receive information from public


databases, marketing partners, social media platforms, and other outside sources.



How do we process your information? We process your information to provide, improve, and


administer our Services, communicate with you, for security and fraud prevention, and to comply


with law. We may also process your information for other purposes with your consent. We process


your information only when we have a valid legal reason to do so.



In what situations and with which parties do we share personal information? We may share


information in specific situations and with specific third parties.



How do we keep your information safe? We have organisational and technical processes and


procedures in place to protect your personal information. However, no electronic transmission over


the internet or information storage technology can be guaranteed to be 100% secure, so we cannot


promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be


able to defeat our security and improperly collect, access, steal, or modify your information.



What are your rights? Depending on where you are located geographically, the applicable privacy


law may mean you have certain rights regarding your personal information.



How do you exercise your rights? The easiest way to exercise your rights is by filling out our data


subject request form available here: 121125811@umail.ucc.ie, or by contacting us. We will consider


and act upon any request in accordance with applicable data protection laws.



Want to learn more about what University College Cork does with any information we collect?



TABLE OF CONTENTS



1. WHAT INFORMATION DO WE COLLECT?


2. HOW DO WE PROCESS YOUR INFORMATION?


3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?


4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?


5. HOW LONG DO WE KEEP YOUR INFORMATION?


6. HOW DO WE KEEP YOUR INFORMATION SAFE?


7. WHAT ARE YOUR PRIVACY RIGHTS?


8. CONTROLS FOR DO-NOT-TRACK FEATURES


9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?


10. DO WE MAKE UPDATES TO THIS NOTICE?


11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?


12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?



1. WHAT INFORMATION DO WE COLLECT?



Personal information you disclose to us



In Short: We collect personal information that you provide to us.



We collect personal information that you voluntarily provide to us when you register on the


Services, express an interest in obtaining information about us or our products and Services, when


you participate in activities on the Services, or otherwise when you contact us.



Personal Information Provided by You. The personal information that we collect depends on the


context of your interactions with us and the Services, the choices you make, and the products and


features you use. The personal information we collect may include the following:



▪ names



▪ phone numbers



▪ email addresses



▪ usernames



▪ passwords



▪ contact preferences



▪ contact or authentication data



▪ billing addresses



Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable


law, we process the following categories of sensitive information:



▪ health data



▪ biometric data



Application Data. If you use our application(s), we also may collect the following information


if you choose to provide us with access or permission:



▪ Mobile Device Access. We may request access or permission to certain features from your



mobile device, including your mobile device's bluetooth, camera, sms


messages, reminders, calendar, microphone, storage, and other features. If you wish to


change our access or permissions, you may do so in your device's settings.



▪ Mobile Device Data. We automatically collect device information (such as your mobile device



ID, model, and manufacturer), operating system, version information and system


configuration information, device and application identification numbers, browser type and


version, hardware model Internet service provider and/or mobile carrier, and Internet


Protocol (IP) address (or proxy server). If you are using our application(s), we may also


collect information about the phone network associated with your mobile device, your mobile


device’s operating system or platform, the type of mobile device you use, your mobile


device’s unique device ID, and information about the features of our application(s) you


accessed.



▪ Push Notifications. We may request to send you push notifications regarding your account or


certain features of the application(s). If you wish to opt out from receiving these types of


communications, you may turn them off in your device's settings.



This information is primarily needed to maintain the security and operation of our application(s), for


troubleshooting, and for our internal analytics and reporting purposes.



All personal information that you provide to us must be true, complete, and accurate, and you must


notify us of any changes to such personal information.



Information collected from other sources



In Short: We may collect limited data from public databases, marketing partners, and other outside


sources.


In order to enhance our ability to provide relevant marketing, offers, and services to you and update


our records, we may obtain information about you from other sources, such as public databases,


joint marketing partners, affiliate programs, data providers, and from other third parties. This


information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or


user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs,


and custom profiles, for purposes of targeted advertising and event promotion.



2. HOW DO WE PROCESS YOUR INFORMATION?



In Short: We process your information to provide, improve, and administer our Services,


communicate with you, for security and fraud prevention, and to comply with law. We may also


process your information for other purposes with your consent.



We process your personal information for a variety of reasons, depending on how you


interact with our Services, including:



▪ To facilitate account creation and authentication and otherwise manage user



accounts. We may process your information so you can create and log in to your account,


as well as keep your account in working order.



▪ To deliver and facilitate delivery of services to the user. We may process your



information to provide you with the requested service.



▪ To request feedback. We may process your information when necessary to request



feedback and to contact you about your use of our Services.



▪ To protect our Services. We may process your information as part of our efforts to


keep our Services safe and secure, including fraud monitoring and prevention.



▪ To save or protect an individual's vital interest. We may process your information



when necessary to save or protect an individual’s vital interest, such as to prevent


harm.



3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR


INFORMATION?



In Short: We only process your personal information when we believe it is necessary and we have a


valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply


with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect


your rights, or to fulfil our legitimate business interests.



The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal


bases we rely on in order to process your personal information. As such, we may rely on the


following legal bases to process your personal information:



▪ Consent. We may process your information if you have given us permission (i.e. consent) to


use your personal information for a specific purpose. You can withdraw your consent at any


time.



▪ Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing


our Services or at your request prior to entering into a contract with you.



▪ Legitimate Interests. We may process your information when we believe it is


reasonably necessary to achieve our legitimate business interests and those


interests do not outweigh your interests and fundamental rights and freedoms. For


example, we may process your personal information for some of the purposes


described in order to:



▪ Diagnose problems and/or prevent fraudulent activities



▪ Understand how our users use our products and services so we can improve user experience



▪ Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law


enforcement body or regulatory agency, exercise or defend our legal rights, or


disclose your information as evidence in litigation in which we are involved.



▪ Vital Interests. We may process your information where we believe it is necessary to


protect your vital interests or the vital interests of a third party, such as situations


involving potential threats to the safety of any person.



In legal terms, we are generally the 'data controller' under European data protection laws of


the personal information described in this privacy notice, since we determine the means


and/or purposes of the data processing we perform. This privacy notice does not apply to


the personal information we process as a 'data processor' on behalf of our customers. In


those situations, the customer that we provide services to and with whom we have entered


into a data processing agreement is the 'data controller' responsible for your personal


information, and we merely process your information on their behalf in accordance with your


instructions. If you want to know more about our customers' privacy practices, you should


read their privacy policies and direct any questions you have to them.



4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL


INFORMATION?



In Short: We may share information in specific situations described in this section and/or with the


following third parties.



We may need to share your personal information in the following situations:



▪ Business Transfers. We may share or transfer your information in connection with, or


during negotiations of, any merger, sale of company assets, financing, or acquisition of all or


a portion of our business to another company.



5. HOW LONG DO WE KEEP YOUR INFORMATION?



In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this


privacy notice unless otherwise required by law.



We will only keep your personal information for as long as it is necessary for the purposes set out in


this privacy notice, unless a longer retention period is required or permitted by law (such as tax,


accounting, or other legal requirements). No purpose in this notice will require us keeping your


personal information for longer than one hundred twenty (120) months past the termination of the


user's account.



When we have no ongoing legitimate business need to process your personal information, we will


either delete or anonymise such information, or, if this is not possible (for example, because your


personal information has been stored in backup archives), then we will securely store your personal


information and isolate it from any further processing until deletion is possible.



6. HOW DO WE KEEP YOUR INFORMATION SAFE?



In Short: We aim to protect your personal information through a system of organisational and


technical security measures.



We have implemented appropriate and reasonable technical and organisational security measures


designed to protect the security of any personal information we process. However, despite our


safeguards and efforts to secure your information, no electronic transmission over the Internet or


information storage technology can be guaranteed to be 100% secure, so we cannot promise or


guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat


our security and improperly collect, access, steal, or modify your information. Although we will do our


best to protect your personal information, transmission of personal information to and from our


Services is at your own risk. You should only access the Services within a secure environment.



7. WHAT ARE YOUR PRIVACY RIGHTS?



In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK),


you have rights that allow you greater access to and control over your personal information. You


may review, change, or terminate your account at any time.



In some regions (like the EEA and UK), you have certain rights under applicable data protection


laws. These may include the right (i) to request access and obtain a copy of your personal


information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal


information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the


right to object to the processing of your personal information. You can make such a request by


contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US


ABOUT THIS NOTICE?' below.



We will consider and act upon any request in accordance with applicable data protection laws.



If you are located in the EEA or UK and you believe we are unlawfully processing your personal


information, you also have the right to complain to your local data protection supervisory authority.



You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.



If you are located in Switzerland, the contact details for the data protection authorities are available


here: https://www.edoeb.admin.ch/edoeb/en/home.html.



Withdrawing your consent: If we are relying on your consent to process your personal


information, you have the right to withdraw your consent at any time. You can withdraw your consent


at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU


CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.



However, please note that this will not affect the lawfulness of the processing before its withdrawal


nor, will it affect the processing of your personal information conducted in reliance on lawful


processing grounds other than consent.



Account Information



If you would at any time like to review or change the information in your account or


terminate your account, you can:



▪ Contact us using the contact information provided.



Upon your request to terminate your account, we will deactivate or delete your account and


information from our active databases. However, we may retain some information in our files to


prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or


comply with applicable legal requirements.



If you have questions or comments about your privacy rights, you may email us


at 121125811@umail.ucc.ie.



8. CONTROLS FOR DO-NOT-TRACK FEATURES



Most web browsers and some mobile operating systems and mobile applications include a Do-Not-


Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data


about your online browsing activities monitored and collected. At this stage no uniform technology


standard for recognising and implementing DNT signals has been finalised. As such, we do not


currently respond to DNT browser signals or any other mechanism that automatically communicates


your choice not to be tracked online. If a standard for online tracking is adopted that we must follow


in the future, we will inform you about that practice in a revised version of this privacy notice.



9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY


RIGHTS?



In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to


your personal information.



California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users


who are California residents to request and obtain from us, once a year and free of charge,


information about categories of personal information (if any) we disclosed to third parties for direct


marketing purposes and the names and addresses of all third parties with which we shared personal


information in the immediately preceding calendar year. If you are a California resident and would


like to make such a request, please submit your request in writing to us using the contact information


provided below.



If you are under 18 years of age, reside in California, and have a registered account with Services,


you have the right to request removal of unwanted data that you publicly post on the Services. To


request removal of such data, please contact us using the contact information provided below and


include the email address associated with your account and a statement that you reside in


California. We will make sure the data is not publicly displayed on the Services, but please be aware


that the data may not be completely or comprehensively removed from all our systems


(e.g. backups, etc.).



10. DO WE MAKE UPDATES TO THIS NOTICE?



In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.



We may update this privacy notice from time to time. The updated version will be indicated by an


updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we


make material changes to this privacy notice, we may notify you either by prominently posting a


notice of such changes or by directly sending you a notification. We encourage you to review this


privacy notice frequently to be informed of how we are protecting your information.



11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?



If you have questions or comments about this notice, you may contact our Data Protection Officer


(DPO), Catriona O'Sullivan, by email at gdpr@ucc.ie, by phone at +353 (0)21 4903949, or by post


to:



University College Cork


Catriona O'Sullivan


Office of Corporate & Legal Affairs


University College Cork


Cork, Co. Cork


Ireland



If you are a resident in the European Economic Area, the 'data controller' of your personal


information is University College Cork. University College Cork has appointed University


College Cork to be its representative in the EEA. You can contact them directly regarding the


processing of your information by University College Cork, by email at gdpr@ucc.ie, or by post


to:



University College Cork


BIS - 3rd Floor, O’Rahilly Building


University College Cork


Cork, Co. Cork T12 K8AF


Ireland



If you have any further questions or comments, you may also contact us by post at the following


corporate address:



University College Cork


BIS - 3rd Floor, O’Rahilly Building


University College Cork


Cork, Co. Cork T12 K8AF


Ireland



12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE


COLLECT FROM YOU?



Based on the applicable laws of your country, you may have the right to request access to the


personal information we collect from you, change that information, or delete it. To request to review,


update, or delete your personal information, please visit: 121125811@umail.ucc.ie.