Privacy and Cookies Policy
WELLBEES PRIVACY AND COOKIES POLICY
- Information we collect about you and how we use it
- Cookies and other technologies
- Who we give your information to
- Where we store and transfer your information
- Child safety
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contacting us
Wellbees is made up of different legal entities:
- Wellbees Inc., with its headquarters at 1401 Pennsylvania Ave. Unit 105 Wilmington, Delaware 19806, which is the holding company of the Wellbees Group.
- Wellbees Limited, with its registered office at 4th Floor Imperial House, 8 Kean Street, London, England, WC2B 4AS.
- Actifit Spor VeSaglik Hizmetleri Sanayi VE Tic A.S, of Maslak Mah, Eski Buyukdere Cad, 14 Park Palza, K:3 Saruter, Turkiye.
- Wellbees DMCC of Jumeirah Lakes Towers, Dubai, United Arab Emirates.
For the UK, Wellbees Inc has appointed Wellbees Ltd as its official representative for all data protection matters.
Full name of legal entity: Wellbees Ltd
Email address: firstname.lastname@example.org
Postal address: 4th Floor Imperial House, 8 Kean Street, London, England, WC2B 4AS
You have the right to make a complaint at any time to the relevant data protection authority. In the UK this is the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Information collected about you and how we use it
The website will collect and process the following personal data from you:
- Information you give usas a website user
This is information you enter directly when you interact with the website. This includes where you:
- Show interest in our services and register with us.
- Sign up to receive marketing information.
- Provide us with additional information.
- Ask questions or submit a query.
This is information about you that you record by filling in forms and using different website features. It includes information to:
● Register your interest with us. We ask for:
Identity information: your first and last name.
Contact information: your business e-mail address and telephone number.
This is so we can register your interest and contact you where appropriate.
● Record information about you: you can enter business details about your business or employer.
Job information: (e.g., your business or employer's name, logo and number of employees).
● Ask questions: if you submit a query regarding the website. We will use the details you provide to investigate and respond.
Identity information: in connection with responding to any questions or enquiries you raise with us.
- Information we collect about you from your use of the website (Usage data): we will automatically collect usage information from you each time you visit the website. This includes:
- Technical information (see below).
- Information about your engagement with the website.
● Technical information: we collect the internet protocol (IP) address used to connect your device to the Internet, browser type (e.g., Apple Safari or Google Chrome) and operating system version information. We also receive information about the content of a request as well as the time zone setting, date and http status code associated with the request.
● Information about your engagement with the website: may include the website session data traffic, including date and time, content viewed or searched for, click details to see the types of content that you click on, content load response times, download errors, and length of session. This is so that we can understand how the website is used and in the case of your searches, display to you ranked feedback, editorial content, summary reports and content relevant to your search terms.
You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed in the table below in the section titled: Purpose and lawful basis for processing of personal data.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Cookies and other technologies
Most browsers automatically accept cookies and similar technologies, but if you prefer, you can change your device privacy settings to enable you to do this. We also give you information about how to disable cookies below. However, you may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your website session and expire when you leave the website. Others are used to remember you when you return to the website and will last for longer.
We use these cookies and other technologies on the basis our legitimate interests (where such cookies are strictly necessary for the operation of the website (and we have considered that these are not overridden by your rights), or otherwise where you have consented to their use.
● Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into your account and manage your session.
● Functional cookies. These enable us, subject to your choices and preferences, to personalise the look or appearance of certain content on the website,
● Analytical/performance cookies. They allow us to recognise and count the number users and to see how they engage with our website content and features. This helps us to identify, ways of improving our website, for example by ensuring that users are finding what they are looking for easily.
You can find more information about the individual cookies we use and the purposes for which we use them below.
|Purpose and duration
|Google Analytics cookie
|These cookies are used to collect information about how visitors use our website. We use the information to compile reports and help us improve the website. (Three months.)
|Yandex Metrica cookies
|These cookies are used to collect information about how visitors use our website. We use the information to compile reports and help us improve the website. (Three months.)
|These cookies are used for form data. (Three months.)
|This cookie is used to understand the cookie consent status. (Three months.)
|This cookie is used to understand the top bar showing status. (One day.)
|This cookie is used to understand the pop up consent status. (Three months.)
Where permitted in our legitimate interest we may communicate specific administrative service messages about your enquiry. We may also where permitted in our legitimate interest or with your prior consent where required by Data Protection Law, use your personal information for analysis or to communicate messages relevant to promoting a better user experience of the website, or to let you know about our other products and services.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Job and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, product/service experience or other transactions (where relevant).
Who we give your information to
We may make personal Information available to:
- A member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for their own purpose, we will only transfer the information to them for that purpose with your prior consent.
- Selected third parties.
Our selected third parties may include:
● Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the website in particular those providing data hosting services, providing fulfilment services, distributing any communications we send, facilitating feedback on our services and providing IT support and development services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only access your information to the extent necessary to perform their support functions.
● Our analytics provider who assists us in the improvement and optimisation of the website and subject to the cookie section of this policy
We may disclose your personal information to third parties:
● If Wellbees or substantially all of its assets are acquired by or merged with a third party, in which case personal data held by it about its customers will be one of the transferred assets.
● If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Wellbees, our end users, or others. This includes:
● sharing information with competent national or regional regulatory authorities where we are obliged to assess, and report information; or
● exchanging information with other companies and organisations for the purposes of fraud protection and to prevent cybercrime.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where we store your information
The information that we collect is hosted on secure servers located within the EEA and Turkey and, may specifically be hosted and or processed on secure servers in the context of the country you reside and where the website is provided, where required by law.
We may transfer your personal information outside the UK and EEA to our group companies in the United States of America, Turkey and the UAE:
● In order support the operation of the services provided by the website.
● Where we are legally required to do so.
● In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
Where we transfer your personal information to a jurisdiction not subject to a relevant legal transfer adequacy finding, we will take steps to ensure an appropriate legal adequacy safeguard is in place which usually means, use of specific approved contracts that rely upon ICO-issued international data transfer agreements ("IDTAs") for the protection of personal data.
For further information on transfers outside of the UK and EEA and/or the specific safeguard methods adopted, please contact email@example.com.
Protecting the safety of children when they use the Internet and online services is important to us. The website is intended for use only by persons who are at least 18 years of age. By using the website you confirm to us that you meet this requirement.
How we protect your information
All information you provide to us is stored on our secure servers. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our website may, from time to time, contain links to external sites. Where you engage with sponsored content on the website that will take you to a third party site we will notify you that you are about to leave the website. We are not responsible for the privacy policies or the content of such sites.
The website does not use personal data to make automated decisions in any way that has any legal effect or significantly affect upon you.
How long we keep your information
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see the section of this policy covering your legal rights for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data,
- to request that your provided personal data be moved to a third party,
- not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or that similarly significantly affect you (note, as stated above, this website does not use personal data to make such automated decisions).
You may opt out at any time from allowing further access by us to your location data by altering the privacy settings of your browser.
Your right to withdraw consent: where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us as set out below.
Where we receive a request to exercise one of the above rights, we will normally respond within one month. This may be extended by up to two further months in cases where requests are complex or numerous and where such an extension is permitted by Data Protection Law. Where that is the case we will inform you within one month of any extension and the reason for this.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You can also exercise the rights listed above at any time by contacting us at firstname.lastname@example.org.
Changes to this policy
Purpose and lawful basis for processing of personal data
This table sets out:
- What personal data we process
- What we use that data for
- The lawful basis for the processing
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register your interest through the website.
|(a) Performance of our terms with you.
To manage our relationship with you which will include:
(b) Responding to your questions and queries
(a) Performance of our terms with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how users engage with the website and our services).
|To enable you to provide further information or partake in a survey.
(a) Necessary for our legitimate interests (to study how users engage with our services, to develop them and grow our business).
(b) Research purposes. Defining and progressing research priorities.
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
To a) deliver relevant content to you;
b) communicate website engagement information by email
(a)Necessary for our legitimate interests (to study how users engage with our services, to develop them, to grow our business and to inform our business strategy).
b) Consent where communication constitutes marketing.
|To use data analytics, crash reporting and push messaging and linking tools to improve our website, products/services.
(a) Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our business and to inform our business strategy).
b) Consent (where applicable to the particular method of collection (e.g. cookies and similar technologies).
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.