PRIVACY POLICY

 

 

•            We collect your personal information when you interact with us or use our services, such as when you use our Sites to place an order. We also look at how visitors use our Sites, to help us improve our services and optimise customer experience.

•            We collect information:

•            when you create an account with us or you change your account settings;

•            when you place an order with us and during the order process (including for payment and order  );

•            when you contact us directly via email, phone, post, message or via our chat function; and

•            when you browse and use our Sites (before and after you create an account with us).

•            We also collect information from third party sites, such as advertising platforms and our fraud detection provider.

 INFORMATION THAT WE COLLECT FROM YOU

•            As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.

•            When you visit the Sites or make a The wellness Collective LTD order through the Sites, you are asked to provide information about yourself including your name, contact details,   address, order details and payment information such as credit or debit card information.

•            We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via e-mail, letter, phone or chat function. If you contact us by phone, we record the call for training and service improvement purposes, and make notes in relation to your call.

•            We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.

•            We also collect technical information about your use of our services through a mobile device, for example, carrier, location data and performance data such as mobile payment methods, interaction with other retail technology such as use of NFC Tags, QR Codes and/or use of mobile vouchers. Unless you have elected to remain anonymous through your device and/or platform settings, this information may be collected and used by us automatically if you use the service through your mobile device(s) via any The wellness Collective LTD mobile application, through your mobile's browser or otherwise.

•            We process health information about you only where you volunteer and consent to this, for example if you specify any health concerns.

USE OF YOUR INFORMATION

•            We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.

•            Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:

•            to enable us to provide you with access to the relevant parts of the Sites;

•            to supply the services you have requested;

•            to enable us to collect payment from you; and

•            to contact you where necessary concerning our services, such as to resolve issues you may have with your order.

•            We also process your data where we have a justifiable reason for doing so— for example personalisation of our service, including processing data to make it easier and faster for you to place orders. We have listed these reasons below:

•            to improve the effectiveness and quality of service that our customers can expect from us in the future;

•            to tailor content that we or our third party   or advertising partners display to you, for example so that we can show you partners which are in your area or make sure you see the advertising which is most relevant to you, based on characteristics determined by us;

•            to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible;

•            to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Sites or our services, including letting you know that our services are operating in a new area, where you have asked us to do so;

•            to analyse your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud;

•            to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of The wellness Collective LTD,   partners, or others (including to prevent fraud); and

•            if you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you live.

•            We will also analyse data about your use of our services from your location data to create profiles relating to you and for you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications, to present you with partners that we think you will prefer, or to let you know about special offers or products which we think you may be interested in (including The wellness Collective LTD for Business). This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see 'Your Rights' section below for more information.

•            Where we rely on legitimate interest as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us using the details above.

•            Where we are under a legal obligation to do so we may use your information to:

•            create a record of your order(s);

•            comply with any legal obligation or regulatory requirement to which we are subject.

DISCLOSURE OF YOUR INFORMATION

•            The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with.

•            Sharing your information internally

•            We share your information with other The wellness Collective LTD group companies only where necessary for the purposes set out in section 4.

•            Sharing your information with third partiesWe share your information with third party service providers. The types of third party service providers whom we share your information with includes:

•            Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us;

•            IT service providers (including cloud providers): for the purposes of data storage and analysis;

•              partners: that you have placed your order with so that they can fulfil your order, be made aware of any health concerns you have volunteered to tell them about, resolve issues, or improve their services;

•            Partners: so they can   your order to you;

•            Customer support partners: who will help us to resolve any issues you may have with our services; and

•            Marketing and advertising partners: so that they can ensure that you see advertising which is more relevant to you and send you email marketing on our behalf.

•            The wellness Collective LTD will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is transferred to third parties.

•            If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

•            We may also share your information:

•            if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention;

•            in order to enforce our contractual terms with you and any other agreement;

•            to protect the rights of The wellness Collective LTD,   partners, or others, including to prevent fraud; and

•            with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police.

•            International transfers of data

•            In some cases the personal data we collect from you might be processed outside the European Economic Area ("EEA"), such as the United States, the Philippines and the countries in which The wellness Collective LTD operates (which are set out on www.The wellness Collective LTD.co.uk). These countries may not have the same protections for your personal data as the EEA has. However, we are obliged to ensure that the personal data that is processed by us and our suppliers outside of the EEA is protected in the same ways as it would be if it was processed within the EEA. There are therefore certain safeguards in place when your data is processed outside of the EEA.

•            We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•            your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

•            we use the EU approved Standard Contractual Clauses; and

•            where your personal data is transferred to third party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework in relation to the type of data being transferred, which requires them to provide similar protection to personal data shared between the EU and the US.

•            Please contact us using the contact details above if you want further information on the countries to which personal data may be transferred and the specific mechanism used by us when transferring your personal data out of the EEA.

RETENTION OF YOUR INFORMATION

•            We will not retain your information for any longer than we think is necessary.

•            Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘Use of my information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.

•            When determining the relevant retention periods, we will take into account factors including:

•            our contractual obligations and rights in relation to the information involved;

•            legal obligation(s) under applicable law to retain data for a certain period of time;

•            statute of limitations under applicable law(s);

•            our legitimate interests where we have carried out balancing tests (see section on 'How we use your personal information' above);

•            (potential) disputes; and

•            guidelines issued by relevant data protection authorities.

•            Otherwise, we securely erase your information where we no longer require your information for the purposes collected.

 

Any changes to our privacy policy will be posted to the Sites and, where appropriate, we will notify you of the changes for example by email or push notification.

This privacy policy was last updated: 22/05/2018

 

YOUR RIGHTS

•            Under data protection law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.

•            The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.

•            The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).

•            The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).

•            The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details).

•            The right to restrict processing. You have rights to 'block' or 'suppress' further use of your information. When processing is restricted, we can still store your information, but will not use it further.

•            The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).

•            The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.

•            The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.

•            The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences or disabling cookies as set out in sections 7 and 8 above.