Welcome to our (WellFitBox LTD) privacy notice.
At WellFitBox LTD we are committed to respect the privacy of all our website (www.wellfitbox.com) visitors and we safeguard all visitors personal data collected through our website.
1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 In this policy, "we", "us" and "our" refer to WellFitBox LTD. For more information about us, see Section 17.
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. The source of the usage data is our analytics tracking system. We refer to this automatically-collected information as “Device Information”. This data may be used order to analyze the use of the website and services. The data is analysed for our legitimate interests in order to monitor and improve our website and services. We collect Device Information using the following technologies:
(a) “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
(b) “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
(c) “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
2.3 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.4 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely performing the actions necessary to deal with your enquiry.
2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data").The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. 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 into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 We may disclose transaction data to our suppliers insofar as reasonably necessary to fulfil our obligations under the contract.
We work with third party service providers and suppliers in order to provide certain services. We may share your personal data some of these supplier with different purposes, please see the following list for further details:
(a) Mailchimp (our email mailing list provider)
(b) Royal Mail, Parcelforce, DPD, etc (our delivery service providers)
(c) Shopify (our ecommerce platform,web and hosting services provider)
(d) Google Analytics (our analytics and search engine provider)
(f) PayPal and Apple Pay (our payment services providers)
(g) regulators, government departments, law enforcement authorities, and tax authorities (when we believe it is appropriate to comply with the law)
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store -you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
3.3 Financial transactions relating to our website and services may be handled by our payment services providers,Shopify & PayPal, Apple Pay, GPay. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:
(a) PayPal: www.paypal.com - https://www.paypal.com/en/webapps/mpp/ua/privacy-full
(b) ApplePay: https://support.apple.com/en-gb/HT203027
(c) GPay: https://support.google.com/pay/answer/7020860?hl=en-GB&visit_id=636742044920030372-3423651793&rd=1
3.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Behavioural advertising
4.1 As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
(a) Facebook: https://www.facebook.com/settings/?tab=ads
(b) Google: https://www.google.com/settings/ads/anonymous
(d) Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
- International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in United States of America and Canada. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.3 We use a series of subcontract organisations for the provision of services such as delivery of transactional emails, newsletter distribution, accounting, reviews and customer relationship management that may be situated in countries about which The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Device and Usage data will be retained indefinitely.
(b) Account & transaction data will be retained for 3 years following the date of your last transaction.
(c) Enquiry data will be retained for 3 years following the date of your enquiry.
(d) Notification data will be retained for 3 years following the date on which you last opened one of our emails.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Information Protection
7.1 To ensure the safety of your personal data we implement a variety of security measures.
7.2 Any data that is submitted from your web browser and to our web server will be protected using encryption technology. All information received is stores using encryption technology, this is to prevent unauthorised access. All your personal data will be stored on secure servers, personal computers and mobile devices will be protected using encryption technology, and in secure manual record-keeping systems.
7.3 As you are aware, unfortunately, the transmission of information via the internet is not completely secure. As part of this Policy, you acknowledge that the transmission of data over the internet is inherently insecure,therefore, although, we will do our best to protect your personal data, and we cannot guarantee the security of data sent over the internet. Please be aware that any transmission is at your own risk.
7.4 Your account is password-protected for your security. Please maintain the privacy of your password and change this password occasionally to maintain a good level of security.
7.4 We regularly review our security and enhance it if necessary.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of significant changes to this policy by email.
- Your rights
9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section
- Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Do not Track
10.1 Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
- Personal data of children
11.1 Our website and services are targeted at persons over the age of 18.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
- About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Cookies used by our service providers
- Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
- Our details
16.1 This website is owned and operated by WellFitBox LTD.
16.2 We are registered in England and Wales under registration number 11484855, and our registered office is at 10b Langland Mansions, 228 Finchley Road, NW3 6QA, London.
16.3 Our principal place of business is at 10b Langland Mansions, 228 Finchley Road, NW3 6QA, London.
16.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by email, using the email address published on our website from time to time.
- Data protection officer
17.1 Our data protection officer's contact details are: firstname.lastname@example.org
17.2 We are registered as a data controller with the UK Information.17.3 Commissioner’s Office. Our data protection registration number is ZA453653.