WELD HEALTH LTD

PRIVACY POLICY for the WELD App (User App)

Privacy Policy 

Date last revised: July 2019.

We are WELD HEALTH LTD, a company incorporated and registered in England and Wales with company number 11518119, whose registered office is at 139 Third Avenue, London, England, W10 4HP (WELD).

We created and now operate the WELD platform to introduce and connect Service Providers, Premises Providers and Users for wellbeing, exercise, lifestyle and diet Sessions, and other related activities.

You have downloaded the WELD App because you want to register as a User. When you register as a User you are doing so under the terms and conditions set out presented to you at the time of registration, as amended and updated from time to time, and available via the link on the WELD App. Where capitalised terms are not defined within this Privacy Policy, they shall have the same meaning as in those terms and conditions described above. 

Privacy Promise

We are committed to protecting and respecting your privacy. 

This policy sets out the basis on which we process your personal data. Please read this privacy policy carefully to understand our views, practices and processing activities and your rights regarding your personal data. 

By using the WELD App, or by otherwise providing us with your personal information, it will be processed as described in this policy. 

WELD is the data controller for personal data collected for the purpose of registering on the WELD App as a User. WELD provides an instant messaging function between the WELD Pro App and the WELD App which allows Service Providers, Premises Providers and Users to message each other, as applicable. WELD retains the right to access the messages sent via the messaging function for the purposes of managing accounts, monitoring compliance with the WELD terms and conditions and investigating complaints.

As a User, you may request access to all your personal data that WELD holds and WELD will send you a report containing such data.

WELD is also the data controller for the personal data it collects and holds about Service Providers and Premises Providers. 

Contact us

If you have any questions about this privacy policy or our data processing activities, please contact us at:

139 Third Avenue, London, England, W10 4HP

support@weldbeing.com

What information do we collect from you?

We will collect and process the following data about you:

· Information you give us.This is information about you that you give us when you register as a User, or by corresponding with us. The information you give us may include your name, address, email address and phone number and financial information. Once you are successfully registered on the WELD App, Service Providers and Premises Providers will only be able to see your name once you have connected with them via the WELD App. 

· Information we collect from your use of our site. When you use the WELD App, we may automatically collect technical information, such as the Internet protocol (IP) address used to connect your device to the Internet, your location when you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service.

· Information we collect throughout our relationship. This is information relating to the Sessions you take, including the Session Costs and the frequency and types of Session, and the number of Users. We may also collect information about which Service Providers you take Sessions with, including the types of SP Services they provide, and which Premises you or the Service Provider books for the Sessions, if applicable.

· Information we receive from other sources.We are working closely with other organisations, including Experian, our third party background check provider, which will provide us with access to any information we ask you to submit to them in order to perform background checks. Such information will include proof of ID and proof of residence.

· Information collected by third parties who enable us to provide our services. When you register and operate as a User on the WELD App, we use a third party payment service provider to process all payments through the WELD App. In providing this service, the third party payment service provider may collect data from you including your name, address, financial information, and any “KYC” information it may need.

Why do we collect this information?

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 with you (for example to provide you access to the WELD App as a User). In this case, if relevant, we may have to cancel your access to the WELD App but we will notify you if this is the case at the time.

We process your personal information for the following reasons:

· Pursuant to a contract in order to:

· process information at your request in order for you to register as a User to take Sessions and book Premises on the WELD App;

· process financial information relating to you at your request in order to set you up an account with the Third Party Payment Provider;

· provide you with access to the WELD App;

· maintain service continuity of the WELD platforms;

· correspond with you in relation to any enquiries or complaints you may have; and

· record information to facilitate your rights under the Cancellation Rules.

· On the basis of your consent:

· Where we rely on your consent for processing this will be brought to your attention when the information is collected from you;

· We will only contact you with direct marketing communications if you consent to us doing so and you have the right to withdraw consent at any time. See the What are your rights? section below for more information.

· In our legitimate interests of providing the best service and improving and growing our business we will process information in order to:

· provide you with a personalised service;

· improve the functionality of the Website and Applications;

· keep our Website and Applications safe and secure;

· understand base and trends in relation to services offered via the WELD App;

· defend against or exercise legal claims and investigate complaints; and

· understand the effectiveness of our marketing.

We will carry out analytics to improve our products and services as set out above.

You have the right to object to processing carried out for our legitimate interests. See the What are your rights? section below for more information.

· To comply with legal requirements relating to:

· the provision of the WELD Services;

· data protection;

· health and safety;

· anti-money laundering;

· fraud investigations;

· assisting law enforcement; and

· any other legal obligations placed on us from time to time.

How long do we keep hold of your information?

• We will keep information      about you for as long as you remain registered as a User with WELD and for      a maximum of 6 years after the end of our relationship with you unless      obligations to our regulators require otherwise or we are required remove      such data from our records. 
• Telephone records. We will keep these up to 6      months from the time the recording was made. 

Who might we share your information with?

For the purposes set out in the ‘Why do we collect this information?’ section above, we will share your personal information with:

· the following categories of third parties, some of whom we appoint to provide services, including:

· the supplier of our Background Check services which, at the time this Privacy Policy was last updated, is Experian Ltd;

· our Third Party Payment Provider;

· cloud based service provider for the instant messaging function; 

· business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you;

· analytics and search engine providers that assist us in the improvement and optimisation of our site;

· User survey providers in order to receive feedback and improve our services. 

· Any member of our group of companies. 

Additionally, we will disclose your personal information to the relevant third party:

· In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

· If we are acquired by a third party, in which case personal data held by us about our 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 Use and other agreements; or to protect the rights, property, or safety of Users, any regulator, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction[BW8] .

How is your data stored and kept secure? 

At WELD, we take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Our Third Party Payment Provider assures us that they will keep all financial information in a tokenised format and stored on secure servers – see their terms here: https://www.mangopay.com/terms/PSP/PSP_MANGOPAY_EN.pdf.

International Transfers

We do not transfer your data outside the European Economic Area (“EEA”) and the Website and WELD App are hosted in the EEA. If in future we do need to transfer your data outside the EEA, we will only do so if adequate protection measures are in place in compliance with data protection legislation.

What are your rights?

Where processing of your personal data is based on consent, you can withdraw that consent at any time.

You have the following rights. You can exercise these rights at any time by contacting us using the contact details above. You have the right:

• to ask us not to process      your personal data for marketing purposes. We will inform you (before      collecting your data) if we intend to use your data for such purposes or      if we intend to disclose your information to any third party for such      purposes;
• To ask us not to process      your personal data where it is processed on the basis of legitimate      interests provided that there are no compelling reasons for that      processing;
• To ask us not to process      your personal data for scientific or historical research purposes, where      relevant, unless the processing is necessary in the public interest.
• to request from us access to      any personal data we may hold about you;
• to ask for the information      we hold about you to be rectified if it is inaccurate or incomplete;
• to ask for data to be erased      provided that the personal data is no longer necessary for the purposes      for which it was collected, you withdraw consent (if the legal basis for      processing is consent), you exercise your right to object, set out below,      and there are no overriding legitimate ground for processing, the data is      unlawfully processed, the data needs to be erased to comply with a legal      obligation or the data is children’s data and was collected in relation to      an offer of information society services;
• to ask for the processing of      that information to be restricted if the accuracy of that data is      contested, the processing is unlawful, the personal data is no longer      necessary for the purposes for which it was collected or you exercise your      right to object (pending verification of whether there are legitimate      grounds for processing);
• to ask for data portability      if the processing is carried out by automated means and the legal basis      for processing is consent or contract.

Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/.

Cookies

We may use cookies and similar technology to distinguish you from other users of the Website and WELD App. This helps us to provide you with a good experience when you use the Website and WELD App and also allows us to improve both.

We use session cookies which are handled by AWS Cognito. Session cookies are temporary cookies which store information that you have input and track your movements within the Website and Apps. These cookies are subsequently deleted after your session is completed or you close your web browser or App.

We use the following cookies for the following purposes:

· Strictly necessary cookies. These cookies (including local storage and similar technologies) are required for your use of the Website, WELD App or related services, such as assisting with your WELD account login, so we can show you the appropriate experience and features such as your WELD account information, booking history, and to edit your account settings. They are also necessary for the security of the Website and authentication.

· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website and WELD App when they are using it. This helps us to understand, improve and research the way the Website and WELD App (and related products, services and ads) work, for example, by ensuring that Service Providers, Premises Providers and Users are finding what they are looking for easily. We can also use this information to understand how you use site features and to segment audiences for feature testing.

· Functionality cookies.These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.

· Targeting cookies.These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

· Site features and Services. We use these cookies to provide you with functionality that help us deliver products and services through the Website and WELD App. These cookies will help to pre-complete fields and make customised suggestions to you, as well as providing social media plugins. 

• Examples: WELD; Facebook; Twitter and Google.

· Advertising. We use cookies and pixels to advertise to you, and to track marketing and advertising performance and efficiency. Our partners also use cookies and similar technologies to identify and monitor the performance of our ads, and give us feedback about your interaction with them. We and our partners will use this information to provide more relevant and interesting advertising to you.

• Examples: Uber; Google; Facebook; Twitter; and LinkedIn.

· Mobile-specific. When you are using the WELD App, some service providers will show you relevant mobile ads and will monitor the performance of this marketing.

• Example: Google.

In relation to the Website, cookies can be controlled by your web browser settings. Whether our cookies are used will depend on your settings, so you are in control. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please use the following links: 

• Internet Explorer cookies      information
• Chrome cookies      information
• Firefox cookies      information
• Safari cookies information

Please be aware that by blocking all cookies you may not be able to access or use all the features of our website and you will not receive a personalised service.

Changes to our privacy policy

This policy may be updated from time to time. Please check back frequently to see any updates or changes to our privacy policy.