This policy sets out our policy on the privacy of the individual. We take your privacy
seriously and information will be used in accordance with the European law and regulation on data
protection (in this policy called “Data Protection Requirements”). This privacy notice aims to
give you information on how we collect and process your personal data through your use of our website
WebWellness.net and/or mobile application WebWellness,
including any data you may provide through this website and/or mobile application when you apply to the
website WebWellness.net, WebWellness mobile
application or otherwise communicate with us.
This mobile application WebWellness and/or website WebWellness.net is not intended
for children and we do not knowingly collect data relating to children unless a parent or guardian has
given consent on behalf of the child. If you are under the age of 18 you should request that your parent or
guardian gives their consent.
It is important that you read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This privacy
notice supplements the other notices and is not intended to override them.
Axioma Life LP is the controller and responsible for your personal
data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact the DPO using the details set out below.
Email address: [email protected]
Postal address: Street: Queen Street No.: 4 Suite 1 City: Edinburgh Post code: EH2
1JE Country: UK Scotland;
You have the right to make a complaint at any time to the EU's independent
data protection authority “EUROPEAN DATA PROTECTION SUPERVISOR” (EDPS),
(https://edps.europa.eu/). We would, however, appreciate the chance to deal with your concerns before you
approach the EDPS so please contact us in the first instance. 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.
Your use of WebWellness application signifies your consent to us collecting and
using personal data about you as specified below in accordance with this policy statement. Should we choose
to change these terms for any reason, the changes will be posted here so that you are always kept informed
about the collection and use of your personal information, and when we disclose it.
- 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 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.
- We separate Personal Data and Sensitive Personal Data and keep them in two independent
databases at high grade secure Google Cloud Storage at Google
- We implement Pseudonymisation for physical or mental health conditions,
biometric data which is considered to be Sensitive Personal Data so that the person, to whom the data
relates, cannot be identified without the use of additional information which is meant to be kept
separately and secure.
- We use high grade encryption with asymmetric keys for Sensitive Personal Data base.
The data we collect about you
- Personal data means any information about an individual from which that person
can be identified. We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together 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
- We do not collect Financial Data which includes
bank account and payment card details;
- Transaction Data includes details about payments to and from you and other
details of services you have purchased from us;
- Technical Data include only your login data you use to access our mobile application or
- Profile Data includes your 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 or mobile
application, products and services;
- Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences;
- We collect Special Categories of Personal Data (Sensitive Personal Data) about
you (this includes details about your health).
How do we collect personal information
about you and how is it used?
- We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact by filling in forms
or by corresponding with us by email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our website or mobile application;
- subscribe to our service or publications;
- request that information about WebWellness.net is sent to you;
- enter a promotion or survey; or
- give us some feedback.
How we use your personal data
- We will only use your personal data when the Data Protection Requirements
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 (or those of a third party) and your
interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation.
- Generally we do not rely on consent as a legal basis for processing your
personal data other than in relation to sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any time by contacting
Purposes for which we will use your
- We may to use your personal data to:
- register you as a new client;
- process your application for setting your WebWellness program including manage
payments, fees and charges;
- manage our relationship with you which will include:
- asking you to leave a review or take a survey;
- enable you to partake in a complete a survey;
- administer and protect our business;
- deliver relevant content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you;
- use data analytics to improve our mobile application, website,
products/services, marketing, customer relationships and experiences;
- make suggestions and recommendations to you about goods or services that may be
of interest to you.
- We may provide aggregate statistics about sales, customers, traffic patterns
and information to third parties, but these statistics will not include any information that identifies
- Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data.
We strive to provide you with choices regarding certain personal
data uses, particularly around marketing and advertising.
- Promotional offers from us
- We may use your Identity, Contact, Technical, Usage and Profile Data 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 and have not opted out of receiving that marketing.
- Third-party marketing
We will get your express opt-in consent before we
share your personal data with any third party for marketing purposes.
- Opting out
- You can ask us to stop sending you marketing messages at any time by contacting us on:
[email protected] or unsubscribing using the link on the
- 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 contact us.
- 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 the Data Protection
Disclosure of your Personal Data
- We may have to share your personal data with
- service providers who provide IT and system administration services;
- professional advisers;
- regulators and other authorities in EEA or Switzerland who require reporting of
processing activities in certain circumstances.
- The personal data disclosed to third parties may:
- relate to performance of our contract with you;
- be necessary for our legitimate interests or to comply with a legal obligation;
- be third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a
change happens to our business, then the new owners may use your personal data in the same way as set
out in this privacy notice.
- We require all third parties to respect the security of your personal data and
to treat it in accordance with the Data Protection Requirements. We do not allow our third-party
service providers to use your personal data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our instructions.
- Some of our external third parties are based outside the 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
- We will only transfer your personal data to countries that have been deemed to
provide an adequate level of protection for personal data by the European Commission. For further
details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
- 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. For further
details, see European Commission: Model contracts for the transfer of personal data to third countries;
- 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
- Please contact us if you want further information on the specific mechanism
used by us when transferring your personal data out of the EEA.
What are cookies and how do we deal with
- A cookie is a piece of information that is stored on your computer's hard
drive. It is normally sent by a web server to you and enables the server to collect information back
from your site visit.
- You can set your browser to refuse all or some browser cookies, or to alert you
this mobile application or website may become inaccessible or not function properly
- 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
- 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.
- In some circumstances you can ask us to delete your data: see [Request erasure]
below for further information.
Your legal rights
- Under certain circumstances, you have rights under Data Protection Requirements
in relation to your personal data.
- 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
- 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
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.
Data Protection Requirements
the right to:
- Request access to your personal data. This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully processing it.
- 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.
- 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.
- 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.
- 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 cases:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
- 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.
- 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.