The Well+ Group understands that your privacy is important to you and that you care about how your personal data is used. Werespect and value the privacy ofeveryone who visits this website, www.thewellplusgroup.com and will only collect and use personal data in ways that are described here, and in a way that is consistent with ourobligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of our Site;|
|“Cookie”||means a small text file placed on your computer or device by ourSite when you visit certain parts our Site and/or when you use certain features of ourSite. Details of the Cookies used by our Site are set out in Part 14, below; and|
|[“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]|
- Information About [Us] OR [Me]
MySite is owned andoperated by The Well Plus Group, a limited company registered in England under company number 10665963.
Registered address: C/O Ross Brooke, 2 Old Bath Road, Newbury, Berkshire, Rg14 1QL
Data Protection Officer: Ria Ingleby
Email address: firstname.lastname@example.org
Telephone number: 07775 862076
I am regulated by Register of Fitness Professionals
I am a member of the C.H.E.K Institute
- What Does This Policy Cover?
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the GDPR, you have the following rights, which wewill always work to uphold:
- The right to access the personal data I hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I have. Please contact me using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to me using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. I do not use your personal data in this way.]
For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Data Do We Collect?
- [Date of birth;]
- [Email address;]
- [Telephone number;]
- [Business name;]
- [Job title;]
- [Payment information;]
- [Information about your preferences and interests;]
- [IP address];
- [Web browser type and version;]
- [Operating system;]
- [A list of URLs starting with a referring site, your activity on my Site, and the site you exit to;]
- How Do You Use My Personal Data?
Under the GDPR, I must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data may be used for the following purposes:
- Providing and managing your Account;
- [Providing and managing your access to mySite;
- Personalising and tailoring your experience on my Site;
- Supplying my products and services to you. Your personal details are required in order for me to enter into a contract with you.
- Personalising and tailoring my products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by updating your settings in the email).
With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message and post with information, news, and offers on my products and services. You will not be sent any unlawful marketing or spam. I work to fully protect your rights and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties (including partners) whose content appears on my Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that I do not control the activities of such third parties, nor the data that they collect and use themselves, and I advise you to check the privacy policies of any such third parties.
I use the following automated system for carrying out certain kinds of profiling. If at any point you wish to query any action that I take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact me to find out more using the details in Part 15.
- The following automated profiling may take place:
- Completion of health and wellbeing surveys and questionnaires to assess your requirements, health priorities and desired outcomes
- How Long Will You Keep My Personal Data?
I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Well+ applies a general rule of keeping your personal information for only as long as is required to fulfill the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations, or where we would like to have an accurate record of your dealings with us in the event of any complaint or challenge.
- How and Where Do You Store or Transfer My Personal Data?
I use specific contracts with external third parties that are approved by the European Commission for the storage of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
I store your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact me using the details below in Part 15 for further information about the particular data protection mechanism used by me when transferring your personal data to a third country.
The security of your personal data is essential to me and to protect your data, I take a number of important measures, including the following:
- Ensuring PtEnhance have the required privacy policies in place that apply under GDPR.
- Do You Share My Personal Data?
I will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, whenyou submit personal data via my Site, you may be given options to restrict my use of your personal data. In particular, I aim to give you strong controls on my use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from me which you may do by unsubscribing using the links provided in my emails and at the point of providing your details and by managing your Account.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Can I Withhold Information?
You may access my Site without providing any personal data at all. However, to use all features and functions available on my Site you may be required to submit or allow for the collection of certain data.
- How Can I Access My Personal Data?
If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell me everything I need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.
Iwill respond to your subject access request within 28 daysand, in any case, not more than one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of myprogress.
Cookies this site uses & how to opt-out
Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling me to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of My Site may not function fully or as intended.
Certain features of my Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that my Site may not work properly if you do so. I have taken great care to ensure that your privacy is not at risk by allowing them.
We have supplied links to several of the more popular browsers for procedures on how to view and disable cookies.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|_cfduid||Used by the content network, Cloudflare, to identify trusted web traffic.||<<yes>>|
|PHPSESSID||Preserves user session state across page requests.||<<yes>>|
|_ga||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||<<no>>|
|_gat||Used by Google Analytics to throttle request rate||<<no>>|
|_IDE||Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.||<<no>>|
|collect||Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across d evices and marketing channels.||<<no>>|
In addition to the controls that I provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]
- How Do I Contact You?
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Ria Ingleby):
Email address: email@example.com
Telephone number: 07775 862076.
I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.