[[ Privacy Policy  ]]

Effective date: [[ 14th January 2021 ]]

Welcome to our Privacy Policy. “Cathy Francis Wright” whose business is registered as “Francis Wright Consultancy” (“We”) (“the Company”, “us”, “we”, or “our”) are committed to protecting and respecting your privacy. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide directly through this website.

  

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

For the purpose of the Data Protection Act 1998 (the Act) and the EU General Data Protection Regulation (GDPR), the data controller is “Cathy Francis Wright” whose business is  registered as “Francis Wright Consultancy” registered in England and Wales.

 

Our nominated data protection representative is Cathy Francis Wright who you may contact to find out more about the way we treat and use personal data via email at

[email protected]

 

You have the right to make a complaint at any time to 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 ICO so please contact us in the first instance.

 

WHO IS THE PRIVACY POLICY FOR? 

 

This privacy policy describes the way we treat and use personal data that we collect about any person that uses our services.

 

IF YOU DO NOT PROVIDE PERSONAL DATA 

 

If we need to process the data you provide us with about yourself to fulfil our service and you fail to provide that data when requested, we may not be able to perform the service, in which case, we may have to cancel a product or service you have with us. We will of course notify you if this is the case at the time.

 

WHAT INFORMATION DO WE USE? 

 

We will collect and process the following data about you:

 

Information you give us about you. 

This is information about you that you give us by filling in forms on our website (www.virtualwellnesshub.com) that you may access directly or through another website, or by corresponding with us by email or otherwise. It only includes basic personal data required for you to be able to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards, and when you report a problem with our website. The information you give us may include:

  • full name
  • e-mail address
  • other personal identification information.

 

  • Information we collect about you.With regard to each of your visits to our website we will automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
  • Information we receive from other sources.This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies). We will notify you when we receive personal data about you from them and the purposes for which we intend to use that information.

 

COOKIES  

 

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

 

HOW DO WE USE THIS INFORMATION? 

 

We will only use 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 and your interests and fundamental rights do not override those interests;
  • where we need to comply with a legal or regulatory obligation;
  • to ensure that our Service is delivered in the most effective manner for you;
  • to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  • to provide customer service to you in relation to your use of the Service, to deal with inquiries and complaints relating to the use of the Service and to notify you about any changes to our service;
  • to administer, support, improve, optimise and develop our Service;
  • to produce reports which may be used, sold, or published by us at our sole discretion provided that any data or reports will be anonymised and not refer to any individual user of the Services;
  • for internal marketing and demographic studies to improve the products and services that we provide; and for security purposes; or
  • we may also use your information to provide you with our email notifications, newsletters and other marketing communications that either you request from us or which you consent to by opting in when completing a registration form on the Service. You may opt out from receiving such marketing communications from us at any time by notifying us in writing, contacting us at [email protected] or, alternatively, by following the procedure to ‘unsubscribe’ that is specified in the email that you receive.

 

MARKETING  

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website 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 goods or services through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

You can ask us to stop sending you marketing messages to you at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at [email protected]

 

 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

THIRD-PARTY MARKETING

 

We will get your express opt-in consent before we share your personal data, including your video footage, with any external company for marketing purposes.

 

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 email us at [email protected]

 

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.

 

HOW DO WE SHARE YOUR INFORMATION?

 

You acknowledge and agree that from time to time we have the right to share your personal information with:

 

Selected third parties including:

  • Facebook Inc. (“Facebook”) based in the US and Ireland, for use of their social media platform;

 

  • Payment Providers: We may provide paid products and/or services within the site. When we do, we use third-party services for payment processing (e.g. payment processors).  We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy notice. The payment processors we work with adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council,which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

 

The payment processors we intend to work with are:

  • Stripe
  • Paypal

and

  • select business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.

 

Other than as expressly set out in this Privacy Policy or as otherwise required or permitted by law, we will not share, sell, or distribute any of the information you provide to us without your consent. We will disclose your personal information to third parties in the following cases:

 

  • Information posted on the public elements of our service may be visible by users of the service throughout the world. You should therefore be careful when submitting information about yourself to our service.
  • we may disclose your personal information: (i) to any third party to whom disclosure is necessary to enable us to fulfil your orders and provide you with any service to which you have subscribed via the Service; (ii) where required to do so by law or court order; and (iii) to any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under our Terms and Conditions.
  • 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 or substantially all of our assets are acquired by a third party, in which case personal data held by it 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 Website Terms and Conditions and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

WHERE DO WE STORE YOUR INFORMATION?

 

For the purposes of IT hosting and maintenance this information is maybe transferred to a cloud service provider which has data servers which are based outside the European Economic Area (“EEA”).

 

Some external third parties such Facebook and Stripe are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

 

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

 

  • Appropriate security measures will be adopted to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

 

Please contact us at [email protected] if you want further information on the specific mechanism used when transferring your personal data out of the EEA.

 

Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.

 

However, and 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 our website at transmission stage; any transmission is at your own risk.

 

HOW LONG DO WE KEEP YOUR INFORMATION FOR? 

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. However, we generally retain your data for two (2) years before we delete it.

 

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 requirements.

 

We are required under UK tax law to keep basic personal data about our customers (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

 

In some circumstances we may 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 policy to you.

 

In some circumstances you can ask us to delete your data. See below for further information.

 

WHAT ARE YOUR RIGHTS? 

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

 

  • Request access to your personal data;
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data;
  • Right to withdraw consent.

 

EXERCISING YOUR RIGHTS

 

If you wish to exercise any of your rights set out above, please email us at [email protected]

 

 

We try to respond to all legitimate requests within one day. Occasionally it may 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.

 

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 may refuse to comply with your request in these circumstances.

 

THIRD-PARTY LINKS  

 

Our service and website may contain links to websites or access to applications that are operated by third parties. We do not control and accept no liability or responsibility for those websites and this Privacy Policy does not apply to those websites. Please consult the terms and conditions and privacy policy of those third-party websites to find out how they collect and use your personal data and to establish whether they use cookies and what they may use them for.

 

Advertisements contained on our website and while delivering you our service operate as links to the advertiser’s website and as such any information, they collect by virtue of you clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

 

CHANGES TO OUR PRIVACY POLICY  

 

Any changes we make to our privacy policy in the future will be posted on this page and notified to you by e-mail. Your continued use of the site following the posting of changes to this policy will be deemed your acceptance of those changes.

 

Contact Us

If you have any questions, concerns or complaints about this [[ Privacy Policy ]], please contact us: