Privacy Notice
Welcome to the Productive Healthy Work Lives privacy notice.
We own and operate a digital platform ("Platform") which can be accessed via a mobile application, and which provides online services designed to assist individual users in managing challenges and build emotional resilience through reflection, using our programme Bravyn.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when we interact with you, including when a company or employer signs up for products or services from us through our Platform (the "Services"). It also sets out how you can control or limit how we use your data, as well as your privacy rights and how the law protects you.
The privacy notice covers situations where we are the data controller (the person who makes decisions around what data is collected and how it is processed), like where we engage with an employer in relation to making our Platform available to employees for use. Where we collect and process personal data from an employee through the Platform, we will process that information as a data processor on behalf of the relevant employer to provide the Services. Any data processor activities we carry out will be covered under appropriate terms and conditions with the relevant company/companies.
Important information about who we are
We are Productive Healthy Work Lives Limited (Company Number SC701833) and responsible for the Platform, and processing of any personal data through the Platform, (collectively referred to as "PHWL", "we", "us" or "our" in this privacy notice).
We have a team who are responsible for overseeing questions relating to this privacy notice and our data protection practices. If you have any questions about this privacy notice, please contact us using the details set out below.
Contact Details
Full name of legal entity: Productive Healthy Work Lives Limited
Email address: support@bravyn.ai
Postal address: Suite 2, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS
UK's Information Commissioner's Office Registration Number: ZB362638
Complaints
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK (where we are based) is the Information Commissioner's Office (www.ico.org.uk). If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible, at the email address above. If you are based in another jurisdiction, you may have additional rights or ability to refer matters to an alternative supervisory body.
Changes to the privacy policy
We keep our privacy policy under regular review and reserve the right to update this privacy policy from time to time. This privacy policy was last updated on 07/03/2025.
Third-party links
Our Platform or website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform or Site, we encourage you to read the privacy policy of every website you visit.
Personal Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal data about you in a variety of ways. Sometimes we collect the personal data directly from you and at times we may receive personal data about you from other sources and third parties. We also collect personal data automatically when you interact with our platform.
The categories of data we collect about you will depend on the relationship we have with you. Where you are a contact of a customer that we engage with to provide our services, we are process the information as a controller, which we have groups together as follows:
Contact Data includes name, address, email address and telephone numbers. In limited cases we will take location data (at country level) as well.
Financial Data includes bank account and payment card details.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website together with information on how you use our website or services.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing and Communications Data includes any preferences you have for receiving marketing from us and our third parties.
Where you are an employee of a customer authorised to use our services, we will collect the following information through the platform to enable you to use the services. We process this as a processor under a contract with your employer.
Account Data includes name, email address, username and password (or other authentication-related information), employer name and job title.
Demographic Data includes additional information about yourself, such as your age, race and ethnicity, sexual orientation, preferred pronouns, gender or gender identity, sex at birth, marital status, and details about your health and medical history.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website together with information on how you use our website or services.
Usage Data includes such as time spent on the Bravyn programme including patterns of use, and the screens accessed on our platform.
Marketing and Communications Data includes any preferences you have for receiving marketing from us and our third parties.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not knowingly collect any Special Category of Personal Data about individuals. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information or genetic and biometric data. We also do not collect criminal conviction or offences data.
Where you are an employee making use of the services, you may provide data where health information can be inferred from as part of your responses. You are not obliged to provide this information and you consent to any processing of this category of data.
Keeping data up to date
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you fail to provide personal data
Where we need to collect personal data by law or contractual terms, and you fail to provide that data when requested, we may not be able to fulfil our contractual obligations. In this case, we may have to cancel the services, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. We will collect some personal data from you directly following meetings in a business context or where you request marketing to be sent to you, any interactions you have with us through the website or any of our social media or give us feedback or contact us.
Automated technologies or interactions. As you interact with our Platform and our website, we will automatically collect Technical Data. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third Party and publicly available sources. We may collect some personal data about you from public sources (like Respondent Data and Company Data). Additionally, Technical Data may be received from third party analytics providers or advertising networks (see our cookie policy for further details).
How we use your personal data
We will only use your personal data when the law allows us to. This includes UK data protection rules (under the UK GDPR and Data Protection Act 2018) and other applicable laws in countries where we collect and process information.
We will not collect and use your personal data without letting you know. Most commonly, we will use your personal data in the following circumstances:
Where you have provided consent (although this is generally not relied on except for marketing purposes). You have the right to withdraw consent at any time, including in relation to marketing, by contacting us or by clicking the "unsubscribe" link provided in any communication.
Where we need to perform the contract we are about to enter into or have entered into with you, your employer or a company you are involved in as a director, agent or other representative.
Where it is necessary for our legitimate interests (or those of a third party). When we process your personal information under this circumstance, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Where our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have another lawful basis for processing your personal data).
Where we need to comply with a legal obligation.
Principles of processing
We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you. We also will not collect any personal data that is not needed for the mentioned purposes.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the tables below.
- To provide our platform and services (the "Services");
- To communicate with you regarding our Services including updates or changes;
- To provide you support, answer your questions or requests for information, or handle your complaints;
- To process payment and manage orders;
- To fulfill our obligations under any agreements that we may have with you;
- To maintain and improve the quality of our Services, including to perform research and development, understand user trends, and, in a limited way, understand the effectiveness of our marketing and advertising such as recording a sales conversion;
- To provide you with information about new products and services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalise, measure, and improve such offers;
- To personalise the advertisements you receive about our Platform through third-party platforms, on other websites and apps;
- To protect ourselves, you and others such as by taking actions to prevent fraud and other unlawful or unauthorised activity, and creating and maintaining a trusted, secure, and reliable online environment;
- To comply with our legal obligations including meeting regulatory compliance obligations, responding to subpoenas, court orders or other legal processes; and
- to establish or exercise our legal rights or defense against legal claims.
Where you are an employee accessing the Services, we will also process your personal data to inform your employer about your registration (including the your registration date, the date on which you last used our Services and other anonymised data about your use of the Services.
Marketing
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of the Platform or Site, or as a result of a product/service purchase.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://ico.org.uk/for-the-public/online/cookies/.
Disclosures of your personal data
We may require to share your personal data with the parties set out below for the purposes set out above:
| Third party | Detail |
|---|---|
| Service providers | Where we appoint third parties to provide services on our behalf and as our processors, such service providers being based in the UK to provide financial transaction and payment services, web hosting and support services and marketing support services. |
| Professional advisers: | including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services. |
| Authorities: | regulatory, government and industry bodies, like ICO, HM Revenue & Customs, fraud prevention organisation or law enforcement bodies who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud. |
| Corporate partners: | includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. |
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers and Data Security
We host all personal data within the EEA based on the decision of the ICO that Europe has adequate level of protection for personal data. Some of our external third party suppliers are based outside the UK. There processing of personal data on our behalf will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO or other appropriate regulatory body; or
- We may use specific contracts approved for use in international transfers which give personal data appropriate levels of protection (like the International Data Transfer Agreement approved by the ICO for international transfers out of the UK); or
- We may rely on another ground or exemption to allow us to transfer the personal data internationally. For example, where you are based out with the United Kingdom and have engaged us for services, we will rely on your consent to transfer data from our UK entity to you in another country.
We know that it is incredibly important to protect and manage personal data appropriately, but unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through our website.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Where we have anonymised your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.
Your legal rights
Under the UK GDPR and Data Protection Act 2018, data subjects have certain rights in relation to your personal data. We have set these out in the below:
| Your Right | What it means |
|---|---|
| Right to be informed | You have the right to be told how we will use your personal data We provide this privacy policy to explain how we use your personal data. |
| Right of access | You can ask us to receive a copy of your personal data, commonly known as a SAR. If you ask, we will confirm how we process your personal data and, in certain cases, provide you with a copy of the personal data we hold about you. There are some exemptions where we do not need to provide copies (like communications we have had with our legal advisers), and we can't give you any personal data about other people or personal data which is linked to ongoing investigations, and we are prevented by law from sharing. |
| Right to rectification | You can ask us to correct your personal data if you think it is wrong or complete if it is incomplete You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided, and we will restrict processing while we verify the accuracy. |
| Right to erasure | You can ask us to delete personal data in certain circumstances If we do not have a reason for holding your personal data and continuing to use it, if you gave us consent and have now withdrawn that consent, you have objected to us using your personal data or we are using it unlawfully, you can ask us to delete it. We might not be able to do this in all circumstances, and we may need to retain information for regulatory purposes. We will always confirm if we cannot delete entirely. |
| Right to restrict processing | In certain circumstances, you can ask us to restrict or suspect use of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data's accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. |
| Right to object | You can object to us processing your personal data for (i) direct marketing or (ii) our own legitimate interests. If you object to direct marketing, we must stop using your personal data for that reason. If we are using legitimate interest, you can object to us using your personal data. But if there is an overriding reason why we need to use your personal data, we do not need to accept your request to stop and can continue to use your personal data. If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won't be able to provide the services |
| Right to data portability | You can ask us to transfer your personal data to you or another company We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. |
If you wish to exercise any of the rights set out above, please contact us on the details above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.