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PRIVACY POLICY

 

What does this policy cover?

This policy describes how Betterminds Live Ltd (also referred to as "Betterminds Live", "we" or "us") will make use of your data when you use our website (www.bettermindslive.com) or purchase goods and services from us.


It also describes your data protection rights, including a right to object to some of the processing which Betterminds carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.


What information do we collect?

We collect and process personal data about you when you interact with us and our website and trainers and when you purchase goods and services from us.

This includes:

  • identity and contact details, including your name, email address, date of birth, gender, and address;
  • payment and delivery details, including billing address and card details, where you make purchases from us;
  • communication information, including metadata, received via emails, SMS, instant messages, and calls you make to us;
  • training requirements, including training needs and notes from sessions ;
  • technical information, including information related to the browser type or version and device type you use to access our website, your IP address, login data, location information, network; and
  • profile information, including username and password, your marketing preferences, including any consent you have given us.

How do we use this information, and what is the legal basis for this use?

We process this personal data for the following purposes:

  • To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or enter a competition we run. This includes:
    • verifying your identity;
    • taking payments;
    • communicating with you;
    • providing customer services and arranging the provision of products or services;
  • As required by Betterminds to conduct our business and pursue our legitimate interests, in particular:
    • we will use your information to provide products and services you have requested, including to respond to any comments or complaints you may send us;
    • we monitor use of our websites and online services, and use your information to help us monitor, improve, troubleshoot and protect our products, content, services and website, both online and offline;
    • we use information you provide to recommend features, products, and services that might be of interest to you, identify your preferences, personalise your experience with Betterminds, including our website, products or services;
    • if you provide a credit or debit card as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud;
    • we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
    • we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
    • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
    • we use data of some individuals to invite them to take part in market research .
  • Where you give us consent :
    • we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us; and
    • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
  • For purposes which are required by law:
    • in response to requests by government or law enforcement authorities conducting an investigation.

Who will we share this data with , where and when?

Personal data may be shared with auditors, regulators, government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on behalf of Betterminds Live for the purposes identified above. Such third parties include providers of website hosting and maintenance, database hosting providers, payment providers, and identity checking providers .

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Transfers outside of the EEA and UK

Where information is transferred outside the EEA and UK, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or under the UK government adequacy regulations or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal data is adequately protected . This includes using the EU Commission approved standard contractual clauses, the UK Information Commissioner approved standard contractual clauses or a vendor's Processor Binding Corporate Rules.

Security of your personal data

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.

We have also 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.
Your rights

You have various rights with respect to our use of your personal data:

  • Access: You have the right to request a copy of the personal data that we hold about you. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
  • Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
  • Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us.
  • Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
  • Erasure: You have the right to ask us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
  • Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts. This is likely to be the Information Commissioner’s Office in the UK.

To exercise any of these rights, you can get in touch with us using the details set out below

For the purchase of our goods and services the provision of information is mandatory: if relevant data is not provided, then we will not be able to accept your offer to purchase goods or services. All other provision of your information is optional, but this may affect your experience of our goods and services, as well as your ability to participate in competitions, for example.

Right to withdraw consent

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

How long we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for .

Updates to this privacy notice

We reserve the right to update and change this notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our notice.

Contact details

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at [email protected].