MY WELLBEING PEOPLE ACCOUNT: PRIVACY POLICY

Wellbeing People Ltd

Privacy and Cookie Policy

31st March 2026

 

 1. Introduction

Wellbeing People Ltd (we, us, our) is committed to protecting the privacy of everyone who uses our services. This privacy notice explains how we collect, use, store, and share your personal data when you use any of the following services:

  • Interactive Health Kiosk (Health Kiosk) - our on-site health screening kiosks deployed at employer and event locations, which carry out health measurements and may include one or more of our automated assessment programmes (such as Wellbeing Age®, Boomerang, Hydration Quota, and MyMood), depending on the configuration at your screening event;
  • My Wellbeing People Account Portal - our online portal at https://myaccount.wellbeingpeople.com where registered users can view their health data and manage their account;
  • Habits for Health Programme - our structured wellbeing programme accessed through the My Wellbeing People Account Portal, which may be funded or subsidised by an employer.

This notice is provided to fulfil our obligations under Articles 13 and 14 of the UK General Data Protection Regulation (the UK GDPR) and the Data Protection Act 2018 (the DPA 2018). It is an information notice, not a document that requires your acceptance or agreement. Where we rely on your consent as a lawful basis for processing, that consent is collected separately and specifically at the point of data collection.

Where this notice describes processing that applies only to a specific service, that service is identified clearly. Where no specific service is mentioned, the processing applies across all three services.

2. Who We Are

Our services are provided by Wellbeing People Ltd, a limited company registered in England and Wales under company number 07858207. Our registered and main trading address is Woodlands, 25 Caring Lane, Bearsted, Maidstone, Kent, ME14 4NJ. Our VAT number is GB 328 0697 85.

Data Protection Lead: Jacob Neal: jacob.neal@wellbeingpeople.com

If you have any questions about this notice or about how we handle your personal data, please contact our Data Protection Lead using the details above, or see Section 16 for full contact details.

3. Our Data Processor

We use Adlines Limited as our data processor for the technical operation of the Interactive Health Kiosk system and associated data storage. Adlines Limited processes personal data on our behalf and strictly in accordance with our documented instructions, as required by Article 28 of the UK GDPR.

Adlines Limited contact: Steve Ford: technical@adlines.co.uk

4. Scope

This privacy notice applies to your use of the Interactive Health Kiosk, the My Wellbeing People Account Portal, and the Habits for Health Programme. It does not extend to any third-party websites linked from our services. We have no control over how your data is collected, stored, or used by other websites and we advise you to check their privacy policies before providing any data to them.

5. What Data We Collect

The data we collect depends on which service you use. This section sets out the data collected by each service.

5.1 Interactive Health Kiosk

When you use an Interactive Health Kiosk, we collect the following personal data:

•      Name

•      Date of birth

•      Gender

•      Height

•      Weight

•      Email address

•      Postcode

We also collect the following special category data (as defined by Article 9 of the UK GDPR):

•      Ethnicity

•      Body fat percentage

•      Body mass index (BMI)

•      Blood pressure (systolic and diastolic)

•      Heart rate (resting)

•      Hydration level

•      Health questionnaire responses (including smoking habits and sleeping habits)

•   Hydration questionnaire responses (where the Hydration Quota programme is active at your screening event)

•  Mood self-assessment responses and associated multiple-choice responses about factors affecting your mood (where the MyMood programme is active at your screening event)

The Interactive Health Kiosk also generates the following derived data from the above inputs. Depending on the configuration at your screening event, the kiosk may include some or all of the following:

  • Wellbeing Age® score - a single numerical score calculated automatically by a proprietary algorithm using five of your measurements: blood pressure, resting heart rate, BMI, sleeping habits, and smoking habits (see Section 11 for further details)
  • Boomerang lifestyle scores - scores from 0 to 9 across ten lifestyle categories (Your Body, Sleep, Exercise, Relaxation, Work Life, Home Life, Stress, Diet, Alcohol, and Smoking) derived from your questionnaire responses, together with an automated summary identifying your highest and lowest scoring areas (see Section 11 for further details)
  • Hydration Quota - an estimated number of additional cups of water you should drink per day, calculated from your hydration questionnaire responses and other health metrics including gender (see Section 11 for further details)
  • MyMood assessment - a mood indicator based on your self-reported emotional state (selected from a five-point scale) and your responses about factors affecting your mood. Where appropriate, MyMood may signpost you to support services such as your employer’s Employee Assistance Programme (EAP) or occupational health provider. No personal data is shared with these services (see Section 11 for further details)

5.2 My Wellbeing People Account Portal

When you register for a My Wellbeing People Account, we collect the data listed in Section 5.1 (where you have previously used a health kiosk) plus:

•      Account credentials (email address and password)

•      Personal challenge goals and achievements

•      Any additional questionnaire responses you choose to complete

5.3 Habits for Health Programme

If you participate in the Habits for Health Programme, we may additionally collect:

•      Your name and the wellbeing resources you access within the programme

•      Your employer’s name and the discount or access code used


 5.4 Automatically Collected Data (Website Only)

When you visit the My Wellbeing People Account website, we automatically collect:

•      IP address

•      Web browser type and version

•      Operating system

•      Referring site URL, pages visited, and exit URL

This data is collected via cookies and analytics tools. See Section 13 for details.

6. Lawful Bases for Processing

Under Article 6 of the UK GDPR, we must have a lawful basis for processing your personal data. The bases we rely on are:

6.1 Article 6 Bases

  • Consent (Article 6(1)(a)): You give us your consent to process your personal data when you use the Interactive Health Kiosk, register for a My Wellbeing People Account, or opt in to marketing communications.
  • Contractual necessity (Article 6(1)(b)): Processing is necessary to provide you with the My Wellbeing People Account Portal and the Habits for Health Programme where you have registered for these services.
  • Legitimate interests (Article 6(1)(f)): We have a legitimate interest in using anonymised and aggregated data for research, analysis, and service improvement. We have assessed that this does not override your rights and freedoms, as the data cannot identify you.
  • Legal obligation (Article 6(1)(c)): Where we are required by law to retain or disclose personal data.

6.2 Special Category Data — Article 9 Conditions

The health data and ethnicity data collected through the Interactive Health Kiosk are ‘special category data’ under Article 9 of the UK GDPR. Processing of this data requires an additional condition beyond an Article 6 basis.

We rely on the following Article 9(2) condition:

•      Explicit consent (Article 9(2)(a)): Before any health measurements are taken or ethnicity data is collected at the kiosk, you are asked to provide your explicit consent to the processing of this data. This includes consent to the generation of your Wellbeing Age® score, Boomerang lifestyle scores, Hydration Quota, and MyMood assessment (where these programmes are active at your screening event). You may withdraw this consent at any time by contacting us (see Section 16).

7. How We Use Your Data

We use your personal data for the following purposes:

  • Providing and managing your Health MOT screening and results
  • Calculating your Wellbeing Age® score using our proprietary algorithm (where active at your screening event)
  • Generating your Boomerang lifestyle assessment scores and summary (where active at your screening event)
  • Calculating your Hydration Quota recommendation (where active at your screening event)
  • Generating your MyMood assessment and, where appropriate, signposting you to relevant support services (where active at your screening event)
  • Displaying your health measurements alongside evidence-based reference ranges so you can compare your results
  • Providing and managing your My Wellbeing People Account and Habits for Health Programme access 
  • Emailing you your Health MOT results, where you have provided your email address for this purpose
  • Responding to your communications and enquiries
  • Anonymised and aggregated research and analysis to identify health and wellbeing trends (this data cannot identify individuals)
  • Improving our services and user experience
  • Marketing communications, where you have given consent (you may unsubscribe at any time using the link in any marketing email)

We will not send you unsolicited marketing or spam. Where we send marketing communications, we comply with the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.

8. How and Where We Store Your Data

8.1 Retention Periods

We only keep your data for as long as necessary for the purposes described in this notice. Our retention periods are:

  • Health MOT data, Wellbeing Age® scores, Boomerang scores, Hydration Quota results, MyMood responses, and user account data: 7 years from the date of your last interaction with our services.
  • Automatically collected website data: Retained in accordance with our analytics provider’s standard retention settings (see Section 13).

We conduct an annual review to confirm that retained data is still necessary. Data that is no longer needed is securely deleted in accordance with our data retention policy.

8.2 Location of Data

Your personal data is stored within the United Kingdom. We do not transfer your data outside the UK.

8.3 Security Measures

We take data security seriously and have implemented the following measures to protect your data:

  • Data is held in a password-protected SQL database, at an ISO 27001:2013 certified data centre within England
  • Your data is stored and processed on Microsoft Azure cloud infrastructure, managed by our data processor Adlines Ltd, using UK-based data centres
  • Your password is stored using a one-way hash algorithm, meaning your actual password cannot be retrieved
  • Internal access to data operates on a minimum-permission basis to prevent unauthorised access
  • Penetration testing has been carried out on our systems

Notwithstanding these measures, transmission of data via the internet may not be completely secure. You are advised to take suitable precautions when transmitting data to us.

9. Who We Share Your Data With

9.1 Data Processor

We share personal data with Adlines Limited, our data processor, who operates the technical infrastructure for the Interactive Health Kiosk system. This sharing is governed by a written data processing agreement in accordance with Article 28 of the UK GDPR.

9.2 Habits for Health Programme - Employer Sharing

If you participate in the Habits for Health Programme and your access has been funded or subsidised by your employer, your name and the wellbeing resources you access may be shared with that employer. This sharing:

  • Only applies to the Habits for Health Programme accessed via the My Wellbeing People Account Portal - it does not apply to Health MOT Kiosk data
  • Only occurs after you have given your explicit consent via a separate consent screen within the My Wellbeing People Account Portal
  • Covers the period from when you use the employer-provided access code to when your programme access ends or is renewed
  • Is limited to your name and the resources accessed - no health measurement data, Wellbeing Age® scores, Boomerang scores, Hydration Quota results, MyMood responses, kiosk results, or other personal data is shared with your employer

9.3 MyMood Signposting

Where the MyMood programme is active at your screening event, it may signpost you to support services such as your employer’s Employee Assistance Programme (EAP) or occupational health provider. This is informational only,  no personal data is shared with these services by Wellbeing People Ltd. Any contact you subsequently make with those services is a separate relationship and will be subject to their own privacy policies.

9.4 Anonymised and Aggregated Data

We may compile anonymised and aggregated statistics about the use of our services, including trends and averages drawn from Health MOT data, Wellbeing Age® scores, Boomerang scores, Hydration Quota results, and MyMood responses. This data cannot identify any individual. Where any data segment within an aggregated report contains three or fewer individual records, that segment is automatically excluded from the report to prevent any possibility of re-identification. We may share such data with third parties such as research partners for purposes related to health and wellbeing research.

9.5 Legal Requirements

In certain circumstances we may be legally required to share personal data, for example where we are involved in legal proceedings, complying with legislation, a court order, or a governmental authority. We will comply with any legally binding request made of us.

10. What Happens if Our Business Changes Hands

We may from time to time expand or reduce our business, and this may involve the sale or transfer of control of all or part of our business. Personal data that is relevant to any part of the business being transferred would be transferred along with it.

In the event of such a transfer, the new controller would be required to comply with UK GDPR. We would take reasonable steps to notify affected individuals before or as soon as practicable after any such transfer, and to inform you of your rights in relation to the new controller, in accordance with our transparency obligations under Articles 13 and 14 of the UK GDPR.

11. Automated Processing

The Interactive Health Kiosk carries out several types of automated processing during your screening session. Depending on the configuration at your screening event, the kiosk may include some or all of the following programmes. This section explains what automated processing takes place, the logic involved, and what it means for you.

11.1 Health Measurement Comparisons

The kiosk compares your individual health measurements (such as blood pressure, BMI, and body fat percentage) against evidence-based reference ranges derived from published clinical guidelines. This comparison is performed automatically at the time of your screening. Your results are displayed alongside the relevant reference ranges so you can see how your measurements compare.

11.2 Wellbeing Age®

The Health Kiosk calculates a Wellbeing Age® score using a proprietary algorithm. This algorithm takes five of your measurements - blood pressure, resting heart rate, BMI, sleeping habits, and smoking habits, and cross-references them to produce a single Wellbeing Age® score. The score is designed to reflect longevity and optimal wellbeing rather than focusing solely on weight or muscle mass. Your Wellbeing Age® is displayed to you on the kiosk screen at the end of your screening session.

Logic involved: The algorithm compares your five input measurements against reference values associated with different age profiles and calculates an age score that reflects your overall wellbeing position. A Wellbeing Age® higher than your actual age suggests areas for improvement; a lower score suggests positive wellbeing indicators.

Significance and consequences: The Wellbeing Age® score is informational. It is intended to help you understand your general wellbeing position and to motivate positive lifestyle changes. It is not a medical diagnosis, does not constitute medical advice, and should not be used as a substitute for professional medical guidance.

11.3 Boomerang Lifestyle Assessment

The Interactive Health Kiosk includes a lifestyle questionnaire called Boomerang. Based on your responses, the kiosk automatically generates scores from 0 to 9 across ten lifestyle categories: Your Body, Sleep, Exercise, Relaxation, Work Life, Home Life, Stress, Diet, Alcohol, and Smoking. These scores are displayed on a radar chart with colour-coded zones:

  • Green (7–9): Good
  • Amber (4–6): Room for improvement
  • Red (0–3): Act now

The Interactive Health Kiosk also generates an automated text summary identifying your highest and lowest scoring categories (for example, ‘You scored highest in Work Life and you scored lowest in Sleep’).

Logic involved: Your questionnaire responses are scored against a predefined scale for each lifestyle category. The highest and lowest scores are identified automatically to generate the summary statement.

Significance and consequences: The Boomerang scores and summary are informational. They are intended to help you reflect on your lifestyle balance and identify areas you may wish to focus on. They do not constitute medical or professional advice.

11.4 Hydration Quota

The Interactive Health Kiosk includes a hydration assessment called Hydration Quota. Through a series of questions and answers, the Hydration Quota calculates whether you are adequately hydrated and whether you should increase your daily consumption of fluid. The output is an estimated number of additional cups of water you should drink per day, calculated from your questionnaire responses and other health metrics including gender.

Logic involved: Your questionnaire responses are assessed against hydration guidelines, taking into account relevant health metrics such as gender, to generate a personalised fluid intake recommendation.

Significance and consequences: The Hydration Quota recommendation is informational. It is intended to help you understand your hydration levels and encourage adequate fluid intake. It is not a medical diagnosis, does not constitute medical advice, and should not be used as a substitute for professional medical guidance.

11.5 MyMood

The Interactive Health Kiosk includes a mental resilience assessment called MyMood. MyMood asks you to select a mood indicator from a five-point scale (represented as faces ranging from upset to happy) and then asks you to select from multiple-choice options about why you feel that way. MyMood is designed to help you understand how you are feeling and why you might feel that way.

Where your responses indicate it may be helpful, MyMood may signpost you to a single support service, such as your employer’s Employee Assistance Programme (EAP) or occupational health provider, for further support. No personal data is shared with these services by Wellbeing People Ltd; the signposting is informational only.

Logic involved: Your mood selection and multiple-choice responses are assessed against predefined criteria to determine whether signposting to a support service is appropriate.

Significance and consequences: The MyMood assessment is informational. It is intended to help you reflect on your emotional wellbeing and to connect you with relevant support where appropriate. It is not a clinical mental health assessment, does not constitute medical or psychological advice, and should not be used as a substitute for professional support. The mood indicator and associated responses are stored as part of your kiosk session data but no score or clinical category is generated.

11.6 Article 22 - Automated Decision-Making

None of the automated processing described above produces decisions that have a legal effect on you or similarly significantly affect you within the meaning of Article 22 of the UK GDPR. The outputs (health comparisons, Wellbeing Age® score, Boomerang scores, Hydration Quota recommendation, and MyMood assessment) are informational and are provided to help you understand your health, lifestyle, and wellbeing. No automated decisions are made that affect your access to services, your employment, or any other legal or significant matter.

12. Your Rights Under UK GDPR

Under the UK GDPR, you have the following rights in relation to your personal data:

  • Right of access - you can request a copy of the personal data we hold about you
  • Right to rectification - you can request that we correct inaccurate personal data
  • Right to erasure - you can request that we delete your personal data in certain circumstances
  • Right to restrict processing - you can request that we limit how we use your data
  • Right to data portability - you can request a machine-readable copy of data you have provided to us
  • Right to object - you can object to processing based on legitimate interests
  • Right to withdraw consent - where we rely on your consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal
  • Right to complain - you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk

You can exercise your right of access, rectification, and erasure by logging into your My Wellbeing People Account using your email address and password. For any other requests, or if you do not have an account, please contact our Data Protection Lead (see Section 16).

13. Cookies

This section applies to the My Wellbeing People Account Portal website only. The Interactive Health Kiosks do not use cookies.

13.1 What Are Cookies

Cookies are small text files placed on your computer or device when you visit our website. They help us provide and improve our services.

13.2 Consent

Before non-essential cookies are placed on your device, you will be shown a cookie consent banner requesting your permission. Strictly necessary cookies do not require your consent, but you may block them by adjusting your browser settings (though this may affect website functionality).

13.3 First Party Cookies

Cookie Name Purpose Strictly Necessary
PHPSESSID Records your visit with a unique session ID (not personally identifiable) No
window_width Stores browser window width for formatting Yes
window_height Stores browser window height for formatting Yes
cookie_agree Records that you have consented to cookies No
browser_ok Records browser compatibility status Yes

13.4 Analytics Cookies (Third Party)

Our website uses Google Analytics to understand how visitors use the site. Google Analytics places the following cookies:

Cookie Name Provider Purpose
_ga Google Analytics Distinguishes users
_gat Google Analytics Throttles request rate
_gid Google Analytics Distinguishes users
_gali Google Analytics Records position of analytics code

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. You can also manage cookies through your browser settings. Deleting cookies may result in loss of login and personalisation settings.