1 Who we are
We are Welbot Limited, a company registered in Scotland (company number SC569751) whose registered office is at Trinity House, 29 Lynedoch Street, Glasgow, Scotland, G3 6EF.
We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation.
2 How to contact us
If you have any questions about this privacy notice or our data protection policies generally, please contact us: By post: St Ninian's Manse, 1A Quayside Mills, Leith, Edinburgh, EH6 6EX By email: firstname.lastname@example.org
3 Privacy notice
3.1 We are committed to protecting your personal data and your privacy. This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, or that we acquire through a third party, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
3.2 Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data.
3.3 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.
3.4 The data protection law in the UK changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a timely request for the transfer of all your personal data) as we are still working towards getting our systems updated and aligned with some of the changes.
3.5 This version of our privacy notice was last updated on 31/05/2018.
4 Visitors to the website
4.2 How is your information used? We use your information collected automatically from our Website to improve the customer experience and functionality of our Website. We do not use such information for any form of automatic decision-making, including profiling.
4.3 With whom do we share your information? Google Analytics will have access to the Website visitor information. We do not permit Google Analytics to access or process your data except in accordance with our instructions.
4.4 Third-party websites Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
4.5 Lawful processing When we process your personal data for the purposes of improving our Website, we do so on the basis of our legitimate interests in maintaining a relevant and functioning website and improving customer experience.
Cookies are small text files that are placed on your computer by websites that you visit. 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.
6 People who use our services
6.1 What information do we collect and process?
6.1.1 Telephone - When you call us, we will collect your name and telephone number, and where relevant, we may collect other details including other contact details and information relating to any contract for products or services relating to you.
6.1.2 E-mail - When you e-mail us, we will collect your name, e-mail address and the contents of your message and any attachments.
6.1.3 Website/Application contact forms - When you fill out any of our contact forms, we may collect:
- Your name;
- Your email address;
- Your age;
- Your height and weight; and
- Other information relating to your fitness and health.
6.1.4 Post - If you send us a letter or other correspondence by post, we may collect any personal data contained in such correspondence.
6.1.5 Contract - Where you create an account with us to use our products and services, we will collect personal data about you from your use of our products and services.
6.1.6 Anonymised Aggregated Data - We also collect, use and share anonymised aggregated data such as statistical or demographic data for any purpose. Aggregated anonymised data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your personal data to calculate the percentage of users accessing a specific Application feature. However, if we combine or connect anonymised 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 notice.
6.2 How is your information used?
6.2.1 We may use any information obtained by telephone, e-mail, Website /Application, contact forms or other media to handle customer and other enquiries, including addressing any complaints. This may include contacting you to discuss any such enquiries or complaints.
6.2.2 We may use any information obtained by telephone, e-mail, Website/Application contact form or other media to provide our services to you via the Application.
6.2.3 We may monitor e-mails and other electronic messages for security reasons. We use e-mail monitoring or blocking software (spam filters).
6.2.4 We may also use any personal data obtained by telephone, e-mail, Website/Application contact form or other media to improve our internal processes, including staff training and quality control.
6.3 With whom do we share your information? We may use third parties to develop or provide our services, and these third parties will have access to your personal data that we store. The third parties we use are data processors and will only process your personal data on our instructions and subject to obligations of confidentiality.
6.4 If you fail to provide personal data 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 into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time
6.5 Lawful basis of processing
6.5.1 When we process your personal data in connection with telephone calls, e-mails, Website/Application contact forms or other media, we do so on the basis of our legitimate interests in responding to customer and other queries and in creating and retaining records of such communications for training purposes and for evidentiary purposes.
6.5.2 Where you are an existing or prospective customer, we process your personal data arising from telephone calls, e-mails, Website/Application contact forms or media on the basis of performance of a contract with you (or steps necessary to enter into such a contract in the case of prospective customers) where such communications are relevant to such a contract.
6.5.3 We will collect "special categories" of personal data through our Website/Application contact form or other media. We may also generate special categories of personal data through your use of the Application. Special categories of personal data includes health data. In order to lawfully process special category personal data, we must have a lawful basis to do so and also have your explicit consent for such processing. Our lawful basis for processing special category personal data (except in the case of where we anonymise special category personal data - see clause 6.5.4 below) which you provide us or is generated by us is so we may fulfil our contract with you. Where we collect special category personal data through our Website/Application contact form or we generate special category personal data through your use of our services then we do this only with your explicit consent, and this explicit consent is granted via our consent forms. You have the right to withdraw consent to the processing of your special category personal data at any time, however we may not be able to provide our full services to you if you do withdraw consent to such processing.
6.5.4 Where we anonymise personal data in accordance with clause 6.1.6 above, and the personal data contains special categories of personal data, our lawful basis for anonymising special category personal data is that such processing is necessary for our legitimate interests (to develop our products/services and grow our business). We will also require your explicit consent to anonymise special category personal data and we will request this via our consent forms. You have the right to withdraw consent to the anonymisation of your special category personal data at any time.
7 How long do we retain your data?
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.
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 will only use your personal data for direct marketing purposes where you have consented to be contacted for such purposes. We do not share your personal details with any third party for their marketing purposes. You have the right to withdraw consent to marketing at any time by contacting us using the details above.
9 Additional Information
9.1 Compliance with legal obligations, etc. We may process (including disclose) your personal data in order to comply with any legal obligations binding on us; to protect the rights, property, or safety of our staff, our customers, or others; and to establish, exercise or defend our legal rights.
When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with a legal obligation to which we are subject or necessary in order to protect the vital interests of a natural person, respectively or necessary in order to pursue our legitimate interests in exercising our legal rights.
9.2 Corporate governance We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal data to third parties:
9.2.1 in the event that we sell or buy any business or assets, in which case we may if relevant disclose your personal data to the prospective seller or buyer of such business or assets; or
9.2.2 if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets. When we process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives.
10 Data transfers
10.1 We do not transfer personal data outside of the European Economic Area (EEA).
10.2 Where you use the Application in a country outside the EEA, your personal data will be transferred to and processed in the country from where you have accessed it. You acknowledge and agree that such a transfer of your personal data out with the EEA is entirely your responsibility.
11 Data Security
11.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only named 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.
11.2 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.
12 Your rights
12.1 Your personal data is protected by legal rights, which include your rights:
12.1.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
12.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
12.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
12.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
12.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
12.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
12.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12.2 If you want to exercise any of these rights, please contact us using the details in section 2.
12.3 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.
12.4 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 contact us at using the details above. 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.
12.5 You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data.