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Our Privacy Promise & Policy and Cookies & similar technologies

Privacy Promise

“The Wellbeing Edit Ltd” (TWE) is committed to protecting the privacy of our customers whilst improving people’s quality of life by enabling them to make healthier choices.

When it comes to health and wellbeing, we know that one size doesn’t fit all, so we’re committed to helping people eat well, move more, sleep better, think clearer and feel great.

We believe in being open and up front with customers and have developed our Privacy Promise, a quick and simple summary explaining how we manage, share and look after your information.

Our Privacy Promise

We promise to collect, process, store and share your data safely and securely:

  • You’re always in control: Your privacy will be respected at all times and we will put you in control of your privacy with easy-to-use tools and clear choices.
  • We work transparently: We will be transparent about the data we collect and how use that data so that you can make fully informed choices and decisions.
  • We operate securely: We will protect the data that you entrust to us via appropriate security measures and controls.
  • For your benefit: When we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.

If you’d like to know more, read our full Privacy Policy below.

Privacy Policy

Our privacy policy will help you understand what information “The Wellbeing Edit” collects, how we use it and what choices you have.

Who we are

1. Who is The Wellbeing Edit?

1.1. “The Wellbeing Edit” (referred to in this policy as “we”, “us” or “our”) is a trading name of:

The Wellbeing Edit Ltd
Registered office:

BM Centre
11 St. Martins Close
Winchester
Hampshire

SO23 0HD

Registered in England and Wales, Company No: 14902687
ICO (Information Commissioner’s Office) registration number: ZB641444

2. Contact details

2.1. If you have any questions, complaints or feedback about your privacy contact in the following ways:

What personal data we collect and how we use it

3. What data we need and why we need it:

This section tells you what personal data we may collect from you and why we need it when you use our services and what other personal data we may receive from other sources.

3.1. When you register for our services, you may provide us with:

  • Your personal details, including your title, name, postal and billing addresses, company name, email addresses, phone numbers and date of birth;
  • Your payment details;
  • Information in relation to your health, including any pre-existing medical conditions;
  • Self assessed information on your health and wellbeing;
  • Personal information about your opinion of your own health and wellbeing;
  • Application survey responses within our wellbeing services;
  • Clinical data taken during a health assessment.

3.2. When you contact us, or we contact you or you take part in promotions, competitions, surveys or questionnaires about our services, we may collect:

  • Personal data you provide about yourself anytime you contact us about our services (for example, your name, username and contact details), including by phone, email or post or when you speak with us via social media.
  • Details of services and/or treatment you have received from us or which have been received from a third party and referred on to us.
  • Notes and reports about your health and any treatment and care you have received and/or need.
  • Information about complaints and incidents.
  • Details of the emails and other digital communications we send to you that you open, including any links in them that you click on.
  • Information collected using cookies stored on your device(s) about the use of our online services.
  • Your feedback and contributions to customer surveys and questionnaires, promotions and competitions that you have entered or taken part in.
  • Where this is the case, the legal basis for processing your data is our legitimate interest to improve our services, grow our business and inform our marketing strategy.

3.3. When you meet us at an exhibition, conference, networking event or seminar, webinar:

  • Your feedback and contributions to customer surveys and questionnaires.
  • Where you have shared your professional contact details with us at an exhibition and provided us with a verbal or written agreement to contact you regarding our services and products we will add you to our marketing database and send you information via our email marketing software.
  • You will have the option to update your preferences or unsubscribe at any time via the links in our emails.
  • Where this is the case, the legal basis for processing your data is our legitimate interest to improve our services, grow our business and inform our marketing strategy.

3.4. What we do with the information we gather? We require information to understand your needs and provide a better service, the information gathered from the following service: Health Assessment (Health Check) on a 1-2-1 basis is used for the following:

  • Personal data relating to your health and wellbeing (medical history, basic clinical information and ethnicity, gender).
  • To provide personalised analysis and reports for you about your own data.

3.5. Personal information may be used in a number of ways, for example:

  • To provide you with a quote
  • To follow up on a quote we provided you with
  • To contact you about a booking
  • To bill you for our services
  • To collect feedback
  • To send booking confirmations and reminders
  • To keep you informed about our services, offers or other information we believe to be of legitimate interest to you

3.6. Treatment consent forms
Individuals receiving a treatment are required to sign a consent form. Your name and signature will be collected but no medical information is recorded. Practitioners provide services for TWE on a freelance basis and it is the individual practitioner’s responsibility to collect and store consent forms.

Where any health issues, medical conditions or considerations which may affect your treatment are disclosed to the practitioner all information shared will be kept strictly confidential and shall only be used for the purpose for which you provide it.

3.7. Photographs

Occasionally, TWE, practitioners or event organisers may take pictures of our practitioners or our customers. This is generally for promotional purposes and for use on our website or social media platforms. We will ask for consent at the time the photograph is taken and it will be separate from our usual terms and conditions. Consent for a client or customer to have their picture taken is not a precondition of signing up to our services.

4. Marketing & Market Research

Here we explain the choices you have when it comes to receiving marketing communications and being invited to take part in market research.

4.1. We use secure third-party systems to store and manage customer data including Zoho systems and Fitech.

4.2. We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications.

4.3. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices online such as unsubscribe at any time via the links in our emails or over the phone or in writing at any time.

4.4. We also like to hear your views to help us to improve our services, so we may contact you to invite you to take part in market research. You always have the choice about whether to take part in our market research.

4.5. Our email marketing provider (Zoho Systems) may transfer data outside of the EEA and when doing so they ensure that they have adequate levels of protection in place to comply with data protection requirements.

4.6. You may see online adverts in social media channels or through customised online marketing as a result of showing interest in our products and services.  See the Cookie Policy section below for more information.

  • Online advertising may be displayed on our websites and on other organisations’ websites and online media channels. We may measure how well our marketing communications perform in order to ensure we send you relevant information.
  • We will ask you to provide us with your preferences to help us send you information that relates to your interests.
  • You can update your preferences or unsubscribe from email and direct mail updates via links in emails we send you or by contacting us and requesting that your preferences are changed.

4.7. Payments we take online are processed by Stripe or PayPal. All payment information is taken through these payment processors and we are not exposed to and do not store any of your financial information. If you make a payment over the phone, we will ask for your credit or debit card details for the purpose of processing the immediate transaction only. We do not store any of your financial details.

4.8. We advise you to make sure you are happy with the privacy policies of Stripe, PayPal and Zoho. We are not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide personal information, without assuring yourselves of the Privacy Policy Statements of the other websites.

5. Understanding our Customers

5.1. We may make use of profiling to produce more relevant and tailored communications by having a deeper understanding of your interests, behaviours and personal preferences. This information helps us provide a better experience for our customers.

5.2. Profiling can help us target our resources more effectively through gaining an insight into the background of our customers and helping us to build relationships that are appropriate to their interests.

5.3. To do this we may use additional external sources of data to increase and enhance the information we hold about you. This may include obtaining details of changes of address, date of birth, telephone numbers and other contact details, information related to your consumption and demographic data generated through software tools such as Acorn.

5.4. If you have any questions in relation to how your information is processed, then please contact us using the information in point 13.

6. Processing your data using our Legitimate Interests

We have a number of lawful reasons that we can use (or ‘process’) your personal data. One of these lawful reasons is called ‘legitimate interests’.

Broadly speaking legitimate interests means that we can process your personal information if:

  • We have a genuine and legitimate reason and we are not harming any of your rights and interests.

The following are some examples of when and why we would use this approach during our normal course of business:

6.1. To improve and enhance our services: When we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.

6.2. Your best interest: Processing your information to protect you against fraud when transacting on our website or through our website, and to ensure our websites and systems are secure.

6.3. Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers.

6.4. Analytics: To process your personal data for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our services and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

6.5. Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.

6.6. Due Diligence: We may need to conduct investigations on existing customers, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.

6.7. Direct Marketing: We may send postal marketing. We will also make sure our postal marketing is relevant for you and tailored to your interests. You also have the right to opt-out of receiving this information at anytime.

6.8. When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Sharing your personal data

7. Third Parties

The only time we share your information with third parties is where it is necessary to fulfil your service we provide.

7.1. We may share your data with our consultants in order to better deliver our services to you or we will give your details to the practitioner visiting your company or giving your treatment.

7.2. In order to provide you with our services, we only share your data with 3rd parties in the following circumstances:

  • We only share data to enable our partners to provide you with a better service.
  • To fulfil your order;
  • To provide the benefits and services for which you have applied;
  • To verify your identity;
  • Authorising debit/credit card payments and any other transactions authorised by the customer;
  • To manage and maintain the accuracy of your records;
  • To handle complaints and improve customer service; and
  • To administer marketing on behalf of The Wellbeing Edit Ltd.

7.3. Sharing data with any organisations other than our partners or suppliers. We do not share your data with any organisations other than our partners or suppliers unless:

  • We are legally required to do so, for purposes of national security, taxation and criminal investigations;
  • We are required to do so in order to protect ourselves against fraud;
  • We sell our business or any part of our business to another company or organisation who then have the right to use your information in the same way as we have outlined in this privacy policy.

7.4. We’ll never make your personal data available to anyone outside The Wellbeing Edit Ltd for them to use for their own marketing purposes without your prior consent.

8. Your data outside Europe

8.1. The EEA is the European Economic Area, which consists of the EU Member States, Iceland, Liechtenstein and Norway. If we transfer your personal data outside the EEA we have to tell you.

8.2. Limited personal data that we collect from you may be transferred to and processed in a destination outside of the EEA. In these circumstances, your personal data will only be transferred on one of the following bases:

  • The country that we send the data is approved by the European Commission as providing an adequate level of protection for personal information; or
  • The recipient has agreed with us standard contractual clauses (SCC’s) approved by the European Commission, obliging the recipient to safeguard the personal information; with Limited situations where your personal data may be transferred outside the EEA are as follows:

Purpose of Processing: Event administration.

Nature of the Data: Name and contact details.

3rd Party: Eventbrite, Inc. t/a “Eventbrite”

Location: USA

Appropriate and Suitable Safeguard: Standard Contractual Clauses (SCCs)

8.3. To find out more about how your personal data is protected when it is transferred outside the EEA (and if you wish to obtain a copy of the appropriate and suitable safeguards), please contact our Office using the details above.

Data security

9. How we look after your data

We will protect the data that you entrust to us via appropriate security measures and controls. We’ll also ensure through the contracts we have in place, that other businesses we work with are just as careful with your data. Below are some of the measures we take to keep your data safe:

9.1. We will always take appropriate technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

9.2. We use safeguards such as data encryption when we transfer your data through The Wellbeing Edit Ltd website and online applications using SSL (you see this as a padlock in your web browser and “https” in the website address).

9.3. We will continually test, audit and monitor our compliance with Information Security standards and relevant Data Protection regulations.

9.4. We may occasionally ask for proof of identity before we share your personal data with you.

9.5. We require our suppliers to uphold data protection regulations and have appropriate systems and practices in place to safeguard your information.

9.6. However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.

9.10. Unfortunately, no data transmission or storage submission can be guaranteed to be 100% secure. TWE uses reasonable measures to protect your data against loss misuse, unauthorised access, disclosure and alteration. Security measures TWE take include firewalls, virus protection, physical access controls to computers and securely locked filing cabinets to paper files.

9.11. If you have reason to believe that the data we have for you or your interaction with us is not secure, please contact us immediately at office@thewellbeingedit.co.uk. We are not responsible for protecting any personal data we share with a third party based on an account connection that you have authorised.

Retention of data

10. How long we hold your data

The length of time we keep your information will depend on what type of information you have provided and for what purpose.

Once your information is no longer required (see below for specific details) we will either delete or anonymise your information (remove all personal identifiable information keeping only information needed for statistical purposes).

If it is not possible to delete your data (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

10.1. Your account information

  • If you have an account with us we will keep your information until you delete your account.
  • Any data which is required for statistical analysis and reporting will be anonymised.

10.2. E-commerce information

  • If you have made a purchase through our website we will keep information regarding your order in line with legal requirements regarding the keeping of company records for accounting purposes. This is currently for 6 years.

10.3. Online programme information

  • Once your programme is complete and your access to the programme is removed we will delete your personal identifiable information and keep only information we need for statistical reporting on the use of the programme.

10.4. 1-2-1 programme

  • If you have worked with us on a 1-2-1 programme we may store your data for up to 12 months after your programme is concluded after which your personal information will be deleted.

10.5. Enquiries and form submissions through our website

  • If you have made an enquiry, sent us your information or applied for a vacancy through our website or online application we will keep your information on our website server for up to 12 months after which it will be deleted.

What can I do?

11. Your rights

11.1. Right to be Informed: We will always be transparent in the way we use your personal data. You will be fully informed about the processing through relevant privacy notices.

11.2. Right to Access: You have a right to request access to the personal data that we hold about you and this should be provided to you. If you would like to request a copy of your personal data, please contact our Office via point 13.

11.3. Right to rectification: We want to make sure that the personal data we hold about you is accurate and up to date. If any of your details are incorrect, please let us know and we will amend them.

11.4. Right to erasure: You have the right to have your data ‘erased’ in the following situations:

  • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed.
  • When you withdraw consent.
  • When you object to the processing and there is no overriding legitimate interest for continuing the processing.
  • When the personal data was unlawfully processed.
  • When the personal data has to be erased in order to comply with a legal obligation.

If you would like to request erasure of your personal data, please contact our Office via point 13. Please note that each request will be reviewed on a case by case basis and where we have a lawful reason to retain the data or where exceptions exist within our retention policy, then it may not be erased.

11.5. Right to restrict processing: You have the right to restrict processing in certain situations such as:

  • Where you contest the accuracy of your personal data, we will restrict the processing until you have verified the accuracy of your personal data.
  • Where you have objected to processing and we are considering whether The Wellbeing Edit’s legitimate grounds override your legitimate grounds.
  • When processing is unlawful and you oppose erasure and request restriction instead.
  • Where The Wellbeing Edit no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

11.6. Right to data portability: You have the right to data portability in certain situations. You have the right to obtain and reuse your personal data for your own purposes via a machine-readable format, such as a .CSV file. If you would like to request portability of your personal data, please contact our Office via point 13, this only applies:

  • To personal data that you have provided to us;
  • Where the processing is based on your consent or for the performance of a contract; and
  • When processing is carried out by automated means.

11.7. Right to object: You have the right to object to the processing of your personal data in the following circumstances:

  • Direct marketing (including profiling). Remember you can opt out at any time from marketing communications via our Marketing Preferences, and
  • Where the processing is based on legitimate interests;
  • Processing for purposes of scientific/historical research and statistics.

11.8. Rights in relation to automated decisions making including profiling: You have the right to not be subject to a decision when it is based on automated processing. If you have any questions in relation to how your information is processed in this way, then please contact our Office using the information in point 13.

Not happy?

12. The Regulator

12.1. If you feel that The Wellbeing Edit Ltd has not upheld your rights, we ask that you contact our Office whose details can be found in point 2.1 so that we can try and help.

12.2. If you are not satisfied with our response, or believe we are not processing your data in accordance with the law you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their details are supplied below:

Address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone:
0303 123 1113

Website:
ico.org.uk

Contact us

13. How to contact us

Registered office:
The Wellbeing Edit Ltd:

BM Centre
11 St. Martins Close
Winchester
Hampshire

SO23 0HD

Telephone:
07856 312948

Email:
office@thewellbeingedit.co.uk

Changes to this Privacy Policy

TWE may revise this privacy policy from time to time to reflect changes in our business or services or changes in the law. We will post the revised policy on our website. You should check this page occasionally to ensure you are happy with any changes made. If the revised version includes a substantial change, we will notify you of the change using email or other means.

Cookies and similar technologies

We use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve your customer experience as you use our website. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

How we use Cookies

Cookies are small data files that allow a website to collect and store data on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our website and we use them to improve your experience. This is non-identifying and aggregate information to produce statistics about sales, traffic and customers that assist with our website design and marketing.

You will see a message on our site before we store a cookie on your computer. You may have options available to manage your cookies preferences. Your browser or internet device may allow you to delete, disable or block certain cookies and other tracking technologies.

If you choose to disable Cookies when using our website you may find that the site does not work as well as it is designed to for example you may see notifications multiple times.

To help our websites and online applications work well for you

Cookies allow us to remember your preferences and whether you have visited our website or seen a notification.

To improve how our Websites and online applications work

Cookies can help us identify whether our site is working as it is supposed to or if you receive an error message whilst you are using the site.

These types of cookies collect anonymous aggregated data and demonstrate how well our website is performing.  E.g. we may collect data on how long visitors stay on our website and how many pages they visit whilst browsing.

Where we have advertised on another organisations’ website you will see the AdChoices icon and you can click on this icon for guidance on how to control your online advertising preferences

Tracking the performance of our online marketing activity

These Cookies may tell us how many times you have seen an advert or visited our website before getting in contact with us and can capture information such as your IP address, your search terms and what website you came from before you visited our website.

Most of the data collected is anonymised and aggregated as statistical information about how well our advertising and website is performing.

If you call us to discuss our services your call may be recorded for training purposes and any record of your call will be kept for up to 6 months pending your decision to instruct us or not.

We may also use Cookies to tell us whether or not you have opened an email we have sent you from our email marketing software e.g. where you have opted in to receive communications from us we will, where relevant, send you notifications when your certificate is due to expire or send you information on upcoming courses.

What can you do to control or manage what Cookies are used?

You can control the cookies on your device through your browser settings choosing to accept or reject new Cookies or delete existing Cookies. You can also manage whether or not you are notified when a website places Cookies on your device.

For more information about Cookies, how to manage them, reject them or delete them visit the All About Cookies website.

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Last updated 06 February, 2024