Privacy Policy | Head On

This Privacy Notice applies between you, the User of our Website and our mobile app (the App), collectively, “the Services”, and DRBAMMENS LIMITED, the owner and provider of the Services .

For the purposes of the GDPR and UK GDPR, DRBAMMENS LIMITED is the controller of the Personal Data that is processed in connection with your use of the Services. Accordingly, as the controller,, DRBAMMENS LIMITED is committed to processing your Personal Data in an open and transparent manner and protecting your privacy. Although this Privacy Notice is a separate document, it can read along with our Terms and Conditions (found here), which also explains how we will use, share, and protect the data we may collect or otherwise obtain about you when you use the Services and when we perform any activities that form part of the operation of the Services. This Privacy Notice also describes your choices and legal rights in relation to such data, the purposes of the processing for which the Personal Data are intended, the legal basis for the processing, and the retention period and storage policy.

Please read this Privacy Notice carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Personal Data	collectively all information that you submit to DRBAMMENS LIMITED via the Services and that can identify you, either directly or indirectly in combination with additional information. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies	a small text file placed on your computer by the Services when you visit certain parts of the Website or when you download the App and/or when you use certain features of the Website. Details of the cookies used by the Services are set out in the clause below (Cookies);
Data Protection Laws	any applicable law relating to the processing of Personal Data, including but not limited to the GDPR, the UK GDPR and the Data Protection Act 2018, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR	the EU and the UK General Data Protection Regulations together;
DRBAMMENS LIMITED, we  or us	DRBAMMENS LIMITED, a company incorporated in England and Wales with registered number 13371782 whose registered office is at Newport House, Newport Road, Stafford, England, ST16 1DA;
UK and EU Cookie Law	the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you	any third party that accesses or uses the Services and is not either (i) employed by DRBAMMENS LIMITED and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to DRBAMMENS LIMITED and accessing or using the Services in connection with the provision of such services; and
Website	the website that you are currently using, https://headon.app, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

1. Please note that this Privacy Notice applies only to Personal Data collected by us in connection with your use of and interaction with the Services and through our performance of any activities that form part of the operation of the Services. This Privacy Notice does not apply to data collected directly by other parties, such as our licensed clients, for their own purposes. Additionally, this Privacy Notice does not apply to your participation in any DRBAMMEN LIMITED’s studies, panels, or surveys or your use of any other applications, websites, or online services administered or provided by any entity affiliated with the DRBAMMEN LIMITED. Other applications and websites, including applications and websites provided by entities affiliated with DRBAMMENS’ group of companies and websites that may be accessible via the Services, are governed by their own privacy notices. We encourage you to review all applicable privacy notices before disclosing any Personal Data.

2. Use of the Services is voluntary. By using or accessing the Website and by downloading and installing the App on your device, you understand that we may collect, use, process, disclose, and retain your Personal Data as described in this Privacy Notice. If you have any questions about this Privacy Notice or how we process your Personal Data, please refer to the “Contact us” section below for our contact information.

3. In this Privacy Notice, unless the context requires a different interpretation:

i.the singular includes the plural and vice versa;

ii.references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Notice;

iii.a reference to a person includes firms, companies, government entities, trusts and partnerships;

iv."including" is understood to mean "including without limitation";

v.reference to any statutory provision includes any modification or amendment of it;

vi.the headings and sub-headings do not form part of this Privacy Notice.

4. Data collected

We may collect or otherwise obtain data relating to you, your mobile device, and your use of the Services from a variety of sources. Additional details about the Personal Data we may collect or otherwise obtain and our data sources can be found below.

We may collect the following Personal Data from you:

i.name;

ii.contact Information such as email addresses and telephone numbers;

iii.IP address (automatically collected);

iv.operating system (automatically collected);

1. How we collect and use your Personal Data

i.We will collect your Personal Data in a number of ways, for example:

a. when you contact us through the Website, the App, by telephone, post, e-mail or through any other means;

b. when you register with us and set up an account to receive our products/services;

c. when you make payments to us, through this Website or otherwise;

d. when you elect to receive marketing communications from us;

e. from third parties like Google Ads and/or Meta,

in each case, in accordance with this Privacy Notice.

ii.

iii.Any or all of the above Personal Data may be required by us from time to time in order to provide the Services to you and also the best possible service and experience. Specifically, Personal Data may be used by us to:

a. operate and manage the Services and customize or personalize your user experience and the content that we deliver to you when you use the Services;

b. operate and manage our IT and security systems, including to monitor such systems and identify and respond to security events;

c. communicate with you about the Services, respond to your inquires and requests, and/or update/validate the data that we hold about you;

d. contact you with information about our business, services, and events as well as other information that may be of interest to you (subject always to obtaining your prior opt-in consent to the extent required under applicable law);

e. conduct research for quality assurance and product, service, and development purposes;

f. prevent, investigate, take action regarding or provide notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of data, the Services, or our data systems;

g. protect the rights, property, operations, health, or safety of you, us or others;

h. respond to subpoenas, court orders, or other legal process/requests and communications from law enforcement authorities or other government officials,

i. to keep internal records;

j. improvement of our products / services;

k. transmission by email of marketing materials that may be of interest to you (subject always to obtaining your prior opt-in consent to the extent required under applicable law);

l. enforce our agreements, comply with applicable laws and regulations, and establish, exercise, and/or defend our legal rights;

2. in each case, in accordance with this Privacy Notice.

9. To the extent that you access the Website or download the App, we may collect your Personal Data automatically, for example:

i.We automatically collect some information about your visit to the Website or use of the App. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

ii.Cookies and similar technologies: We may use Cookies and similar technologies to enable certain features and functionality and collect additional data that helps us improve the Services and better deliver them to you. Specifically, we may use Cookies to identify your browser or device, display information more effectively, provide you with tailored content, and gather statistical data about how you use the Services. We may also use Cookies and other data collection technologies (e.g., web beacons, pixels, or tags) for security purposes and to detect fraud and other risks in order to protect you and other users of our Services. If you do not wish to have data collected from your device by Cookies and/or similar technologies, most browsers and mobile settings allow you to decline the use of not strictly necessary Cookies. Please note, however, that by doing so, some features of the Services may not work properly. To learn more about cookies, including how to see what cookies have been set and how to manage and delete them, please see detailed explanation below and visit http://www.allaboutcookies.org/.

iii.We also use Google Analytics, web analytics services that may set cookies. To learn more about Google Analytics’ data practices, please visit https://support.google.com/analytics/answer/6004245?hl=en. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

10. Legal Basis for Processing your Personal Data.

i.If you are based in the European Union (“EU”)/United Kingdom (UK), we will process your Personal Data for the purposes outlined in this Privacy Notice can be based on one or more of the legal bases listed below.

a. Legitimate interests: We may rely on our legitimate interests, provided that such interests shall not be overridden by your interests, fundamental rights, or freedoms.

b. Consent: We will process your Personal Data based on your prior consent where we are legally required to do it. For example, when collecting Personal Data through not strictly necessary Cookies or when sending marketing communications under some circumstances. You have the right to withdraw your consent at any time. However, consent withdrawal will not affect any processing that took place before the withdrawal.

c. Compliance with legal obligations: We may process your Personal Data if necessary for us to comply with a legal obligation arising under any applicable Data Protection Laws to which we are subject.

d. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

To the extent that we process any special categories of Personal Data relating to you, such as health data, we will do so because either: (i) you have given us your explicit consent to carry out such processing; (ii) the processing is necessary for the establishment, exercise, or defense of legal claims; or (iii) you have made the data manifestly public. If you have any questions or concerns about the legal basis upon which we collect and use your Personal Data, please email us at info@headon.app

12.

Who we share Personal Data with

14. We may share your Personal Data with the following groups of people for the following reasons:

i.third party service providers who provide services to us which require the processing of Personal Data - to provide services, including, but not limited to, the delivery of certain features or services, to ensure the website runs smoothly, to store basic information securely, to send notifications or newsletters to the users.

ii.ii. third party payment providers who process payments made over the Website - to enable third party payment providers to process user payments and refunds and in each case, in accordance with this Privacy Notice.Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.

iii.Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Services or our users.

iv.

Keeping Personal Data secure

15. We will use technical and organisational measures to safeguard your Personal Data, for example:

i.access to your account is controlled by a password and a username that is unique to you.

ii.we store your Personal Data on secure servers.

16. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Personal Data, please let us know immediately by contacting us via this e-mail  info@headon.app.

17. If you want detailed information from, Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by UK Government and leading businesses.

Data retention

18. Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Notice or until you request that the Personal Data be deleted following a data erasure request.

19. Please note that it may not be possible for us to delete your Personal Data if an exception or exemption applies pursuant to the Data Protection Laws, for example if we need it to comply with a legal obligation.

Your choices and legal rights

20. You have choices about how your Personal Data is handled. Depending on your country of residence, under applicable law you may be entitled to the following rights:

i.Right of access - the right to request copies of the information we hold about you at any time and the right to receive certain information about how we process your Personal Data.

ii.Right to rectification - the right to have your Personal Data rectified if it is inaccurate or incomplete.

iii.Right to erasure - the right to request that we delete or remove your Personal Data from our systems.

iv.Right to restrict our use of your Personal Data - the right to "block" us from using your Personal Data or limit the way in which we can use it, under certain circumstances.

v.Right to data portability - the right to request that we move, copy or transfer your Personal Data.

vi.Right to object - the right to object to our use of your Personal Data including where we use it for our legitimate interests.

21. We will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

22. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Data), please contact us via this e-mail  info@headon.app. We may need to verify your identity before fulfilling your request. When doing this, we will avoid collecting any additional information about you unless it is strictly necessary.

23. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your details change during the period for which we hold it.

Transfers outside the United Kingdom and European Economic Area

24. Personal Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK or EEA or one of our service providers is situated in a country outside the UK or EEA. 

25. In cases where your personal data is transferred outside of your country of residence, we will ensure that there are adequate safeguards in place to protect your Personal Data. In case of the EU or UK, this may be tackled for example by way of data transfer agreement, incorporating the current Standard Contractual Clauses adopted by the European Commission or the UK.

24.

Links to other websites

26. Our Services may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Notice does not extend to your use of such websites. You are advised to read the privacy notice or statement of other websites prior to using them.

Changes of business ownership and control

27. DRBAMMENS LIMITED may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of DRBAMMENS LIMITED. Accordingly, Personal Data provided processed about you will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the Personal Data for the purposes for which it was originally supplied to us, after you have been duly informed and all the relevant requirements have been met according to the applicable laws.

28. We may also disclose Personal Data to a prospective purchaser of our business or any part of it.

29. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

30. This Website may place and access certain Cookies on your computer.  DRBAMMENS LIMITED uses Cookies to improve your experience of using the Website.     DRBAMMENS LIMITED has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

31. All Cookies used by this Website are used in accordance with current UK and EU Cookie laws.

32. Before the Services place not strictly necessary Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling DRBAMMENS LIMITED to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Services may not function fully or as intended.

33. This Website may place the following Cookies:

Type of Cookie	Purpose
Strictly necessary cookies	These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies	They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies	These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.
Targeting cookies	These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

34. You can find a list of Cookies that we use in the Cookies Schedule, available below.

35. You can choose to enable or disable Cookies in your internet browser. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.

36. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

37. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

38. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

39. You may not transfer any of your rights under this Privacy Notice to any other person.

40. If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

41. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

42. This Privacy Notice will be governed by and interpreted according to the laws of England and Wales. All disputes arising under this Privacy Notice will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

43. DRBAMMENS LIMITED reserves the right to change this Privacy Notice as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website, and you are deemed to have been informed of the terms of the Privacy Notice on your first use of the Services following the alterations.   You may contact DRBAMMENS LIMITED  by email at info@headon.app.

This privacy policy was created on 16 May 2023.

Cookies Schedule

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Strictly necessary

We use the following strictly necessary cookies:

Description

Purpose

We use this session cookie to remember you and maintain your session whilst you are using our website

We use this session cookie for when a user wants to contact us through the website form. 

Functionality

We use this cookie to identify your computer and analyse traffic patterns on our website

Analytical/performance

We use this cookie to help us analyse how users use the website

Targeting

We use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet