This Website is owned by TruWellbeing (hereafter “Company”) , registered as a sole trader.

We take user privacy seriously and take reasonable efforts to protect it. We have created this Privacy Policy (hereafter “Policy”) in order to share with you our information collection and use practices. AS MORE CLEARLY DEFINED HEREIN, WE WILL NEVER KNOWINGLY SELL OR ASSIGN YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE AND/OR APPROVAL. Please read this Policy carefully before sharing any personally identifiable information described below.

By using, registering or placing an order on this website, you consent to the collection, use and transfer of your information under the terms of this policy. Since this is a growing web site and because Internet technologies are constantly evolving, this Policy is subject to change at any time and any changes will be posted on this page.

This Policy works hand-in-hand with the Terms and Conditions of Use, found elsewhere on the web site.

For the purposes of the Data protection Act 1998, the Data Controller is Bianca Flood of 23 Lockyer Street, Plymouth PL1 2QZ

What personally identifiable information does the Company collect and how is it used?

When you visit, register or order products or services on you may be asked to provide certain information about yourself including your name, email address, home or business address and other information. The Company will not collect personally identifiable information from users while they use the web site, unless they voluntarily provide it to us or authorise us to collect such information. Users may provide other information about themselves, in addition to the mandatory personal information (hereafter “Voluntary Information”).

The Company may use or disclose personally identifiable information to:

  • Operate and manage the Company web site;
  • Enable you to participate in interactive features of our service, when you choose to do so;
  • Provide products/services that have been requested by you;
  • Respond to other inquiries or requests by you.
  • Provide you with information about specials, sales or new products or services that the Company will introduce in the future.

In order to provide the best services, the Company may disclose your name on certain pages at . We may also disclose personally identifiable information in the establishment or exercise of legal rights or defences against legal claims, to comply with applicable laws or regulations, to comply with a valid legal process, such as a search warrant, subpoena or court order or to investigate suspected fraud or a violation of our Terms and Conditions of Use. We will never sell user information to any 3rd-party not affiliated with the Company, without consent, except in connection with the sale or merger of the Company or the division responsible for such services provided.

The Company may also use such Voluntary Information for marketing its products and services to you unless you have ‘opted out’ of receiving such marketing information from us. User may ‘opt out’ by contacting TruWellbeing at 23 Lockyer Street, Plymouth Devon PL1 2QZ or emailing bflood@truwellbeing.com .

The Company may, from time to time, send or post surveys or requests for your feedback in order to help us make our web site and services better. Any responses we receive from users will be used only to evaluate our web site and services and no personally identifiable information from respondents will be shared with any non-employees of Company, except that information provided in the Feedback/Comments areas.

The Company may, from time to time, send notices about special offers, promotions or contests. If you sign up to participate in any of these, we will collect your email address. If you are chosen for a promotion or as a winner in a contest, you give the Company permission to use your name, image and other information about you, for marketing purposes.

To maintain customer service standards and to assist staff training, we may record and monitor incoming calls.

What non-personally identifiable information does the company collect and how is it used?

The Company collects and tracks certain non-personally identifiable information, including, but not limited to, IP numbers and browser type, access times, domain names, usage habits and other information which does not specifically identify any individual.

The Company may use and disclose non-personally identifiable information for any number of reasons, including but not limited to, working with business partners and improving our web site and services

Who we are

Truwellbeing Life, health and relationship coaching. Our website address is: https://truwellbeing.com.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms and email subscription

By signing up to the newsletter you consent to receiving email, direct email and customized online advertising.

You can unsubscribe at any time by clicking the link in the footer of our emails. For information about our privacy practices, please visit our website.

We use Mailchimp as our marketing platform. By clickig below to subscribe, you acknowledge that your information will be transferred to Mailchimp for processing. Learn more about Mailchimp's privacy practices here.

Cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Does TruWellbeing have a newsletter?

The Company regularly sends out a Newsletter via email (hereinafter “Newsletter”) to all Users (unless they have ‘opted-out’). In these Newsletters, we may inform you about new features from TruWellbeing and about the upcoming week’s events or special promotions.

User may choose to unsubscribe from the Newsletter at any time by sending an email to bflood@truwellbeing.com.

Disclosure of your information

You agree that we may disclose your identity and contact details to (1) any third party who claims to us that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights or their rights of privacy, and (2) to other companies and organisations for the purposes of fraud protection and credit risk reduction.

Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

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 site; any transmission is at your own risk.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

GDPR

Who is collecting the data?

Bianca Flood – TruWellbeing

23 Lockyer Street,

Plymouth, Devon

PL1 2QZ

Email address: bflood@truwellbeing.com

Telephone: 01752 603690

What data is being collected?

Email subscriber

sForename

sSurname

sEmail address

Private client

sForename

sSurname

sEmail address

sAddress

sTelephone numbers (home/mobile)

ŸOccupation & hours worked

ŸWellbeing History:       disabilities/health/life challenges

therapy, under medical or mental health care supervision or support, other self-help or support group

Business client

sForename

sSurname

sEmail address

sBusiness name

sBusiness address

sBusiness URL

sBusiness telephone number

What is the legal basis for processing the data?

sContact information – to inform you with information of events/meeting, provide coaching materials, copy of receipts and newsletter and confirm appointments

ŸTo ensure services are suitable for client.

How we protect your personal data

We will not transfer your personal data outside the EEA without your consent.

We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

How will the information be used? Will the data be shared with any third parties?

When someone visits www.truwellbeing.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

As part of the registration process for our monthly e-newsletter, we collect personal information. We use that information for a couple of reasons: to tell you about stuff you’ve asked us to tell you about; to contact you if we need to obtain or provide additional information; to check our records are right and to check every now and then that you’re happy and satisfied. We don't rent or trade email lists with other organisations and businesses.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.

We use a third-party providers, MailChimp and GoDaddy, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice  GoDaddy privacy policyYou can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer : Bianca Flood mailto:bflood@truwellbeing.com

Our EMS provider is Mailchimp & GoDaddy We hold the following information about you within our EMS system;

Email address

I.P address

Subscription time & date

Google analytics

By using the website and clicking OK to the privacy agreement the user agrees to consent to the use of Google analytics to inform marketing decisions. This information is not shared.

Please refer to their privacy policy for information Google 

When you purchase a service, gift voucher or become a member through truwellbeing.com or Bianca Flood (T/A) Truwellbeing your name, address data, email and contact number will be stored in our CRM system, Hubspot. Name & telephone number will be stored on the mobile phone (backed up by google – bgiadrini@gmail.com) Microsoft outlook also will retain a copy of your email address and emails sent. Financial transactions will be stored via quickbooks/freeagent.

Please be assured that we do not share your personal details with any other company without your consent.

We may share anonymised personal information with other organisations, who use this to analyse our social impact programmes.  Many of the events run by Truwellbeing are presented in partnership with other wellbeing organisations and promoters, such as Eventbrite.  We will let them know about your booking and share your name and contact details with them but they can’t contact you unless you select either the Email or Post option under ‘I would like to hear about events, news and offers from the artists or companies presenting the events I’ve booked’ as part of your booking online, in person or over the phone.  We will not share sensitive information or your payment details.”

How long will the data be stored for?

We will hold your personal data on our systems for as long as you are a member of TruWellbeing and for as long afterwards as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment exercise or defence of legal claims.If you have participated in services, then anonymous notes may be retained for research and development purposes.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights does the data subject have?

You have rights under the GDPR:

(a) to access your personal data

(b) to be provided with information about how your personal data is processed

(c) to have your personal data corrected

(d) to have your personal data erased in certain circumstances

(e) to object to or restrict how your personal data is processed

(f) to have your personal data transferred to yourself or to another business in certain circumstances.

You are entitled to view, amend, or delete the personal information that we hold.

You may automatically review, amend or delete the personal information held in Mailchimp. If the account is amended or deleted then this will trigger a manual process which will delete all other contact information. You will receive an email to confirm your request has been processed. As this is a manual process, please allow 10 working days for confirmation of deletion.

If you prefer, you may email your request to our data protection officer Bianca Flood at bflood@truwellbeing.com.

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, look for the box that you can click to indicates you allow the information to be used by Truwellbeing for direct marketing purposes
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email address]

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Data breach procedures

Please see additional policy – Data Breach Policy

ICO Data Protection Register

We are exempt from registration in the ICO Data Protection Register because

the only processing we carry out is for one or more ‘core business purposes’. These are:

  • advertising, marketing and public relations
  • accounts and records.

How can the data subject raise a complaint?

In the event of a complaint, please contact Bianca Flood.

Email: bflood@truwellbeing.com

 

Telephone: 07764 363716

Address:  23 Lockyer Street, Plymouth. PL1 2QZ

You have the right to take any complaints about how we process your personal data to the Information Commissioner:

https://ico.org.uk/concerns/0303 123 1113.

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

For more details, please address any questions, comments and requests regarding our data processing practices to the Bianca Flood at Truwellbeing, 23 Lockyer Street, Plymouth. PL1 2QZ 2SJ via email address bflood@truwellbeing.com.

Type of information Collected Lawful Purposes  Legal basis of processing Data retention period Sharing your information
Clients name, address, telephone numbers, e-mail address(es). Manually entered onto Truwellbeing database Website Contact form Managing the clients requirements and service Performing the companies contract with the client.For the purposes of our legitimate interests in operating the company. 36 Months Backed up onto Google Drive
Client’s name, address, telephone numbers, e-mail address(es). Manually entered Managing the client’s financial transactions with Truwellbeing on the company’s finance system QuickBooks/ Freeagent. Performing the contract with the client.For the purposes of our legitimate interests in operating the Company. 36 Months Backed up onto Google Drive
Ÿ Occupation & hours workedŸ Wellbeing History: disabilities/health/life challengesŸ Therapy, under medical or mental health care supervision or support, other self-help or support group Manually entered To check and ensure that life coaching services are suitable for the client. For the purposes of our legitimate interests in operating the Company.For the purposes of protecting the interests of the client. 36 Months Backed up onto Google Drive
Email addressI.P addressSubscription time & date Collected from webformCollected from manual registration form Managing the clients requirements and service Legitimate Interests: Processing is necessary to the legitimate interests of an organization or a third-party affiliate. 36 Months GoDaddy / Mailchimp
I.P address (cookies) Google analytics Informing ConsewntThe data subject has freely given consent for their information to be processed for a specific purpose. 38 Months Google Analytics

Does the Company use cookies?

Cookies are small text files that a website can write to your computer. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use cookies to identify you and allow you to log in once to our web site and search or post without having to log in again and again. Cookies are also used by our affiliates or links to identify you as a User of TruWellbeing.

The following is a summary of the types of cookies that are being used on this site, along with information on how you can block them.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

The Company does not use Cookies to store information such as credit card numbers, telephone numbers, or other information you provide.

This Privacy Policy only covers the use of Cookies by TruWellbeing. It does not cover the use of Cookies by any other 3rd-party or advertisers.

Cookies that we use are;

[list of cookies used]

Is my information private with company merchants and advertisers?

The Company web site may contain links to various 3rd-party web sites and the external web sites of our advertisers and/or 3rd-party partners. Each of these web sites may have a privacy policy that differs from that of the Company. This Policy does not cover the privacy policies of other web sites. We urge you to check the privacy policies of each web site that you may visit or interact with.

The only Voluntary Information that may be shared between Company and one of our partner web sites is that which pertains to information used in the furtherance of tracking an order and providing you with correct information regarding same.

Order information, including order numbers and amounts, may be available to the Company, affiliate merchants and 3rd-party affiliate program management companies, for accurate tracking purposes. The Company will not release this information to other parties unless you request it.

The Company provides banner and other advertising on its web site, from Google and other third parties, that may place and read cookies on your browser, or use web beacons to collect information in the course of advertisements being served. If you are concerned about your privacy regarding these advertisements, please refer to Google’s (or other third party) privacy policies.

What about data security?

We employ security measures to protect, so far as reasonably possible, your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires or permits.

The Company requires that our advertisers and partners ensure the security of the data that users provide to them, however, in the event of a breach of their security measures, you agree that the Company will not be liable for any losses or damages.

The Company limits access to personal information about users to employees, for whom we reasonably believe it is necessary, in order to provide products or services.

May I see the information the Company collects about me?

You are entitled to see the personal information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at . We are entitled by law to charge a fee of £10 to meet our costs in providing you with details of the information we hold about you, but we may at our discretion waive this charge.

Can I Opt-out?

The Company gives users the option to remove personally identifiable information from our list of active users.

You may also choose to opt-out of certain communications from the Company, such as our Newsletter.

If you want to unsubscribe or opt-out of communications from us, send an email bflood@truwellbeing.com.

The Company is not responsible for removing personally identifiable information from the lists of any 3rd-party partner or advertiser who has previously been provided your information in accordance with this Policy.

Where is the web site located?

The Company web site is maintained in the United Kingdom. If you are located outside of the U.K., by using the web site, you authorise the import of your information and its use, as specified in this Policy.

What is the minimum age to use this website?

Use of and products/services are intended for persons who are eighteen (18) years or older, or business entities.

If proof comes to the attention of the Company that an individual user is under the age of eighteen (18) years, and is accessing our services and/or products without the consent, approval or authorisation of their parents or legal guardian, the Company will immediately terminate such account.

Will there be changes to this Privacy Policy?

The Company reserves the right to amend this Policy at any time, in the event that this becomes necessary after initial release, or in the event that it becomes necessary with respect to additional, deleted, modified or amended services provided by Company.

The Company will not personally notify you of any amendments to this Policy. Users are urged to check this Policy frequently in order to determine whether any changes have been made. Users understand and agree that continued use of the Company web site assumes that they have read and accepted this Policy, as it may be amended from time to time.

Where can I access this policy?

This Policy is accessible from the Home Page of the Company web site, under the link “Privacy Policy”.

Spyware

The Company never uses or installs spyware on user computers, nor do we use spy ware to retrieve information from user computers.

Section Titles

The section titles used in this Policy are purely for convenience and carry with them no legal or contractual effect.

Payment Partners

The Company accepts Stripe as a payment option, and all users are subject to their individual terms of use, privacy policies and other legal requirements, which users can review at the following links: https://stripe.com/gb/legal

Users are encouraged to review the Terms of Use, Privacy Policy and other legal disclosures of payment partners.

Contact

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to Bianca Flood, 23 Lockyer Street, Plymouth PL1 2QZ .

What is the effective date of this privacy policy?

This Privacy Policy was last updated, and became effective, on 09/01/2019.