1. Introduction1.1 We are committed to safeguarding the privacy of our website visitors.1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; 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 In this policy, "we", "us" and "our" refer to ThriveWell Global Limited. Company Number: 04077487. For more information about us, see Section 18.
2. How we use your personal data2.1 In this Section 2 we have set out:(a) the general categories of personal data that we may process;(b) the purposes for which we may process personal data; and(c) the legal bases of the processing.2.2 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.2.3 We may process your website user 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 or 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.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.2.5 We may process your personal data that are provided in the course of the use of our services ("service data”). 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.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.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. The customer relationship data may be processed or 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.2.9 We may process information relating to transactions, including purchases of goods and/or 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 source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and/or 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; providing that, if you are not the person contracting with us, the legal basis for this processing is 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. 2.11 We may process information contained in or relating to any communication that you send to us ("communication data"). The communication 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 communication 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 communications with our website visitors and service users and the proper administration of our website and business.2.12 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.2.13 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 others3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.3.2 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.3.3 Your personal data is held in our website database and will be stored on the servers of our hosting services provider's dropbox.3.4 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. International transfers of your personal data4.1 The hosting facilities for our website are situated in Australia.4.2 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.4.3 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If we store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with.
5. Retaining and deleting personal data5.1 Section 5 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. 5.2 We only keep your data for as long as we need to in order to use it as described, and/or for as long as we have your permission to keep it. In any event, your data will be deleted if you notify us via email, telephone or post5.3 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.
6. Security of personal data6.1 We will take appropriate technical and organisational precautions to secure your personal data and prevent the loss, misuse or alteration of your personal data.6.2 We will store all your personal data on secure servers, personal computers and mobile devices.6.3 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.6.4 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).
7. Your rights7.1 In this Section 8, 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 - you can ask for copies of your personal data;(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;(c) the right to erasure - you can ask us to erase your personal data;(d) the right to restrict processing - you can ask use to restrict the processing of your personal data;(e) the right to object to processing - you can object to the processing of your personal data;(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.7.3 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.7.4 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.7.5 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.7.6 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.7.7 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 data 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.7.8 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.7.9 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.7.10 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.7.11 If you consider that our processing of your personal data 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.7.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.7.13 You may exercise any of your rights in relation to your personal data by written notice to us.
8. Third-party websites8.1 Our website includes 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. Personal data of children9.1 Our website and services are targeted at persons over the age of 16.9.2 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.
10. Updating information10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies11.1 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.11.2 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.11.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use12.1 We use cookies for the following purposes:(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website and to help us determine if you are logged into our website(b) analysis - we use cookies to help us to analyse the use and performance of our website and services(c) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally
13. Cookies used by our service providers13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.13.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy. 13.3 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
14. Managing cookies14.1 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 (Chrome);(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).14.2 Blocking all cookies will have a negative impact upon the usability of many websites.14.3 If you block cookies, you will not be able to use all the features on our website.
15. Amendments15.1 We may update this policy from time to time by publishing a new version on our website.15.2 You should check this page occasionally to ensure you are happy with any changes to this policy.15.3 We may notify you of significant changes to this policy by email.
16. Our details16.1 This website is owned and operated by ThriveWell Global Limited.16.2 We are registered in England and Wales under registration number, and our registered office is at 15 Pipers Court, Chester, CH2 3JL.16.3 You can contact us:(a) by using our website contact form;(b) by telephone, on the contact number published on our website; or(c) by email, using the email address published on our website.
17. Data protection registration17.1 We are registered as a data controller with the UK Information Commissioner's Office.17.2 Our data protection registration number is ZA694202. 
18. Representative within the European Union18.1 Our representative within the European Union with respect to our obligations under data protection law is Cara Cunniff and you can contact our representative by emailing .labolg.llewevirht%40arac
19. Data protection officer19.1 Our data protection officer's contact details are: .labolg.llewevirht%40arac