Privacy policy

What personal information Biowell Health Ltd collects, why we hold it, who it is shared with and the rights you have over it.

Last updated 3 September 2024 · Biowell Health Ltd, company number 14546305

Our Approach to Privacy
- Biowell Health respects your privacy and is committed to protecting your personal data. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) when you use our website or App or otherwise interact with us, including when contacting us via telephone or email (together the “Services”).

About us
- Biowell Health Limited (Company number 14546325) is the data controller of the personal information we hold about you.
- Our registered and postal address is C/O React Business Services City Pavilion, Cannon Green, 27 Bush Lane, London, EC4R 0AA#
- Our data protection officer can be contacted at info@biowell.health.

Changes to the privacy policy and your duty to inform us of changes
- We keep our privacy policy under regular review. This policy is the current and most up to date version and was updated August 2024.
- 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.

Data
- The data we collect
  - Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
    - Identity Data
      includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    - Contact Data
      includes billing address, delivery address, email address and telephone numbers.
    - Financial Data
      includes bank account and payment card details.
    - Transaction Data
      includes details about payments to and from you and other details of products and services you have purchased from us.
    - Technical Data
      includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
    - Profile Data
      includes [our username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    - Usage Data
      includes information about how you use our website, products and services.
    - Marketing and Communications Data
      includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    - Aggregated Data
      We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
  - The following table sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	IdentityContact	Performance of a contract with you
To deliver you our services including manage payments, fees and charges & collect and recover money owed to us	IdentityContactFinancialTransaction	Performance of a contract with you
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy & asking you to leave a review or take a survey	IdentityContactProfileMarketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	IdentityContactTechnical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	IdentityContactProfileUsageMarketing and CommunicationsTechnical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	TechnicalUsage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	IdentityContactTechnicalUsageProfileMarketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Data Sharing
- Your personal information may be shared with the following, in line with the defined uses in the table above:
  - Service providers: we may share your personal information with third parties and other service providers that perform services for us or on our behalf. This includes:
    - Mindbody Ltd – our software partner who provide the booking platform.
      - You are required to use the Mindbody platform to open an account, purchase and book therapies, membership and packages.
      - We share your name and contact details, and the health data you provide with Mindbody to enable bookings to be made.
      - Mindbody also use your personal information for marketing our services on our behalf;
    - Marketing services agencies.
      - We use a portfolio of marketing partners to send email marketing messages (through Klavyio), manage our social media pages (such as Instagram, LinkedIn, Facebook, TikTok), develop and maintain our website.
      - This may also include providers of data hosting, data centre and storage facilities, communications, surveys and chat facilities, user relationship management, social media platforms, marketing communications, advertising, push notifications, technical support, error reporting and fixing, analytics, verification services and/or fraud prevention.
  - Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
  - Other partners of Biowell Health: where applicable, we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out above.
  - Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and/or the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; (iii) enforce our terms and/or (iv) exercise or protect the rights, property, or personal safety of Biowell Health, other users of our Services, or others. This includes exchanging information with other companies and organisations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
Data Security / Protection
- Appropriate security measures have been put in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, your personal data is limited 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.
Data Retention
- We only retain personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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.
- By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Your Rights in respect of your personal information
- In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
  - Right of access. You have the right to obtain access to your personal information and how we are processing your data.
  - Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
  - Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  - Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  - Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  - Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent (without affecting the lawfulness of our processing prior to you having withdrawn your consent).
  - Right to object: you also have the right, in certain circumstances, to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive or toggling your preferences in your account settings.
- Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
- Exercising your rights
  - If you wish to exercise one of these rights, please contact us using the contact details included within this privacy policy. You may also review, remove and edit some of the personal information you have submitted to us by logging into your account on the app or website.
  - 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.
  - We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
  - No fee usually required
    - 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.
  - You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk.

Website & Cookies
- Use of the Website
  - By using our website, you hereby consent to our Privacy Policy and agree to its terms.
  - In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.
- Information on the website
  - The information contained in this website is for general information purposes only. The information is provided by Biowell Health Ltd and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.
- Website functionality
  - Every effort is made to keep the website up and running smoothly. However, we take no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control
- Links to other websites
  - The Website may contain links to other third party websites that are not owned by the Company and not our responsibility. We have no control over the content of the third party linked websites and we are not responsible for it and we strongly advise you to read and understand the terms and conditions and policies on any third party linked website that you visit.
  - Inclusion of any linked website on the website does not imply our approval or endorsement of the linked website.
- Cookies
  - Our website uses cookies and similar technologies to distinguish you from other users of our services.
  - You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
  - For more information about the cookies we use, please do not hesitate to contact us.
- Other technologies
  - We use pixels or web beacons in direct marketing emails that we send to you. These pixels track whether our email was delivered and opened, the links within the email were clicked and which pages of our website you have visited. They also allow us to collect information such as your IP address, browser, email client type, logs of past interactions, and other similar details. We use this information to measure the performance of our email campaigns, and for analytics.
  - You can always opt-out of our marketing communications by unsubscribing through any communication or by emailing us directly at info@biowell.health.