Privacy Statement and terms of use for ROOM
This Privacy Statement describes how the Erasmus University Rotterdam (hereinafter 'EUR') processes your (personal) data when you use ROOM, a digital system for wellbeing and personal growth. This statement is applicable to (personal) data processed through the ROOM mobile app.
For more (general) information on how the Erasmus University Rotterdam processes personal data, please go to EUR privacy statement. Additionally, the EUR also has a privacy policy. The EUR handles personal data with care and acts within the limits of the General Data Protection Regulation (GDPR).
We may amend this Privacy Statement from time to time.
Last Updated
August 2024
Changes and Notifications
Participants will receive a notice when this statement is updated.
Data controller
In so far personal data is processed through the use of the application, whether or not EUR has access to personal data, or personal data is shared with EUR, the EUR acts as a data controller and, therefore, takes on the responsibilities placed on a data controller by the GDPR. In short, the data controller is responsible for ensuring that personal data is handle in accordance with the law.
About ROOM
ROOM is a mobile app designed to enhance the mental wellbeing of students and improve mental health literacy. It provides evidence-based interactive exercises derived from scientifically validated therapeutic approaches. ROOM is an educational tool and not a substitute for professional mental health services. It is not intended for those with high levels of mental health issues, severe emotional distress, or diagnosed mental health conditions. Users struggling with these are strongly encouraged to seek help from qualified mental health professionals, who have the expertise to provide appropriate assessments, diagnoses, and personalized treatment plans. When completing questionnaires from MapMyself in the app, users with scores higher than normal thresholds will be advised to reach out for further help. This is not a diagnosis, but a suggestion.
ROOM was created by the Student Wellbeing Programme at Erasmus University Rotterdam to offer an accessible and effective prevention tool for students.
For any ROOM-related questions, please contact roomtogrow@eur.nl.
Liability Disclaimer
The contents of the ROOM app, including but not limited to text, graphics, images and other materials (collectively the ‘Content’) are for general informational purposes only and Erasmus University Rotterdam cannot guarantee the accuracy of the Content provided or any output of the ROOM app. The Content is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of a physician or other qualified health providers with any questions or concerns you may have. Never disregard professional medical advice or delay in seeking it because of the Content.
Erasmus University Rotterdam does not assume any liability for errors or omissions in the Content and does not assume responsibility for any adverse effects or consequences resulting from the use of the app. Erasmus University Rotterdam is not liable for any damage resulting from the use of the ROOM app.
FAQ's
- Authentication: Surfconext processes user data in order to authenticate a user’s status as a student or staff of EUR. This data is not shared with EUR and the ROOM user’s identity remains anonymous at all times.
- Use of the Application for improving wellbeing: ROOM processes minimal personal data to provide a personalized experience in-app. This includes recommendations and feedback on input. Additionally, aggregated app usage patterns and recommendation system weights are shared with the EUR to improve the application. This is aggregated and anonymised data and cannot be traced back to the user.
- Authentication: Surfconext uses an ERNA log in details to check a user’s status as an EUR staff or student. This information is not shared with ROOM or EUR.
- Use of the Application for improving wellbeing (in-app use): Gender, national or international student, study level (BA vs MA), wellbeing goals, wellbeing data including mood check-ins (how happy, sad, tired, frustrated, energetic, stressed and relaxed the user feels) and longer questionnaires (e.g. perfectionism, mindfulness, stress levels, values), and app usage data are all stored and processed on the mobile phone.
- Visible by EUR: Aggregated app usage patternsfor all users (which questionnaires are taken, and which exercises are used, saved, and rated) and aggregated weights (ratings and whether or not recommendations have been chosen) for the central recommendation system model are visible by EUR.
Personal data may only be processed if one of the legal bases specified in Article 6 GDPR apply. Hence, in so far personal data is processed, this happens on the basis of the following legal bases:
- Use of the app – agreement with the data subject (for the performance of services)
- Improvement of the app/monitoring how it works – Legitimate interest
- Mood data ( how happy, sad, tired, frustrated, energetic, stressed and relaxed users feel) - consent
Data are processed and stored locally on the mobile device.
EEA stands for the European Economic Area. Within this area the GDPR is applicable and therefore all personal data needs to be processed in accordance with the GDPR.
- Use of the Application for improving wellbeing: Data is processed within the EEA. Personal data processed when using ROOM does not leave the mobile phone.
Privacy Rights
- Use of the Application for improving wellbeing: As a data subject, you have various rights under the GDPR. You have the right to access, rectify, and erase your personal data. You can also restrict or object to the processing of your data and exercise your right to data portability. Refer to the EUR privacy statement for details on your rights within the GDPR. To exercise these rights or obtain more information, please contact roomtogrow@eur.nl. Deleting the app results in deletion of all your personal and log data stored on your phone and stops the further sharing of data with EUR. Aggregated app usage patterns and weights already shared with EUR will not be deleted. Reinstalling the app results in a fresh start.
Data Protection Measures
We value user privacy and take security measures to prevent theft, loss, or otherwise unlawful use of your personal data. Security measures include minimizing access rights, encryption, monitoring, and other state-of-the-art measures.
Data Retention
- Use of the Application for improving wellbeing: Personal data is retained on the mobile phone of the user as long as ROOM is installed and is erased upon deletion.
- Scientific Research: When participating in scientific research, research data is stored for 10 years in line with scientific practice guidelines.
Recommender System
In order to enhance the user experience and make it easier for users to achieve the goal of improving their wellbeing, the ROOM app uses a machine learning system to recommend appropriate exercises to users.
The recommender system offers 3 exercise suggestions to users. These 3 recommendations aim to offer exercises that are most likely to be helpful and enjoyable to the user, and additionally to stimulate exploration of different exercises. The recommendations are based on the following data: daily mood check-ins, questionnaire scores, user demographics, user goals, app usage data (exercises completed and chosen before), previous user ratings of exercises, and time of day.
The recommender system employs a federated learning model to ensure user privacy while delivering personalized recommendations. In federated learning, there is a ‘local model’, which lives on the user’s device, and a ‘general model’, which lives on the cloud. New users start with the latest general model. This model learns locally on the user’s device and personalises to the user. Aggregated weights from the learnings of this local model are sent to the general model, and the general model is improved over time.
Hard-coded rules are embedded within the system to ensure exercises are appropriate for individual users. These are derived from literature and scientific evidence.
While we think the recommender system is beneficial and will help you with selecting the relevant exercises, it does not know all, you have agency.
Questions and Complaints
Contact us via the contact form or email privacy@eur.nl for specific questions or complaints. If you believe your data is processed in breach of the GDPR, contact the Data Protection Officer (DPO) at fg@eur.nl. If you disagree with the outcome of the DPO’s handling of your complaint, you can submit a complaint directly to the Dutch Data Protection Authority.