PRIVACY POLICY

Privacy and Cookies Policy

1. Introduction

1.1    We are committed to safeguarding the privacy of Simone Denny Wellness visitors, customers and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our Simone Denny Wellness visitors, customers and subscribers; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5    In this policy, “we”, “us” and “our” refer to Simone Denny Wellness. For more information about us, see Section 19.

2. 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    We may process data about your use of the Simone Denny Wellness 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 consent OR our legitimate interests, namely monitoring and improving our website and services OR to send you our newsletter updates.

2.3    We may process your account data (“account data“). The account data may include your name and email address OR your physical 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 consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR for programs that you purchased through the website.

2.4    We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR to send you programs that you purchased from the site.

2.5    We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include purchasing products or receiving newsletters. The source of the service data is you. The service 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 consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR to send you programs that you purchased from the site.

2.6    We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR to use as testimonials or customer reviews.

2.7    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 consent.

2.8    We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.

2.9    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.

2.10  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 OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.11  We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed [for the purposes of communicating with you and record-keeping. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website and business and communications with users.

2.12  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense 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.

2.13  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.

2.14  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.

2.15  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1    We never share your information or contact details with third parties unless you have explicitly authorised us to be able to do so (e.g. by entering a giveaway run in conjunction with another company and by opting-in to receive their newsletters).

Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies.

3.2    Financial transactions relating to our website and services are OR may be handled by our payment services providers. 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.

3.3    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.

4. Retaining and deleting personal data

4.1    We retain information you provide to us and which we collect about you, including Personal Information and Personal Data, for so long as we continue to provide services to you and specifically until such time as you request us to delete your Personal Information and Personal Data.

5. Security of personal data

5.1    We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

5.2    We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

5.3    The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

5.4    Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

5.5    You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

5.6    You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

6. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3    We may notify you of changes to this policy by email or through the private messaging system on our website.

7. Your rights

7.1    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.

7.2    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.

7.3    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,

Updating Information

Opt-out – You may opt-out of future email communications by following the unsubscribe links in our emails. You may also notify us at simone@simonedennywellness.com to be removed from the mailing list.

Access – You may access the personal information we have about you by submitting a request to simone@simonedennywellness.com

Amend – You may contact us simone@simonedennywellness.com to amend or update your personal information.

Forget – In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to simone@simonedennywellness.com

8Third party websites

8.1    Our website may include hyperlinks to, and details of, third party websites.

8.2    We have no control over and are not responsible for, the privacy policies and practices of third parties.

9. Acting as a data processor

10. About cookies

The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize Website content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if users deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

11. Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at https://www.google.com/policies/privacy/.

11.3  We use MailChimp – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.  Please refer to Mail Chimps privacy policy for further information.

At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in the Website’s sole discretion.

Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

12. Cookie preferences

12.1  You can manage your preferences relating to the use of cookies on our website by visiting: visit http://www.allaboutcookies.org.

13. Advertising

13. 1  We may use third-party advertising companies to serve content and advertisements when you visit the Website, which may use cookies, as noted above.

13.2  From time to time, the Website may engage in remarketing efforts with third-party

companies, such as Google, Facebook, or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website.

14. Affiliate Program Participation

The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link to an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.

15. Newsletters

On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behaviour will not be passed on to third parties.

16. Our details

Feel free to contact us at simone@simonedennywellness.com