Wecudos Privacy Policy
Last modified: 18/05/2018

INTRODUCTION

Welcome to the WECUDOS LIMITED’s privacy notice.
WECUDOS LIMITED is a company registered in England and Wales under registration number 08096172 whose registered address is 3rd Floor 52 Jermyn Street, London SW1Y 6LX.  We are committed to protecting and respecting your privacy.  This policy (together with our terms of use, terms and conditions and similar agreements and any other documents referred to in any of those documents, together our “Terms”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.wecudos.com you are accepting and consenting to the practices described in this policy. Wecudos Limited (which is also referred to in the Terms as “Wecudos” and “we”, “us” and “our”) respects your privacy and is committed to protecting your personal data. This privacy notice 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. Nothing in these terms will be construed as placing an obligation on us that we are not by law obliged to accept (and any such provision shall be construed as a statement of current intent by us but does not create a binding obligation on us).  If and to the extent that any provision of these terms contradicts applicable law, the applicable law shall apply. Wecudos helps uses social media and electronic communications made available by devices you use (together referred to in this policy as “Your Accounts”) to assist you to interact with medical, health, fitness and well-being advisers and others to whom you grant access (together referred to in this policy as “Your Advisers”).

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

1.1 This privacy notice aims to give you information on how Wecudos collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to accept our services, purchase a product or service or otherwise engage with us.

1.2 Our websites and applications are not intended for children and we do not knowingly collect data relating to children.

1.3 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.

CONTROLLER

1.4 Wecudos Limited is the controller and responsible for your personal data to the extent that it collects it through Your Accounts and as a result of interactions with Your Advisers.

1.5 We have appointed a data privacy manager 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 data privacy manager using the details set out below.

CONTACT DETAILS

1.6 Our full details are:
Full name of legal entity: Wecudos Limited
Title of data privacy manager: Data Privacy Manager
Email address: [dataprivacymanager@Wecudos.com]
Postal address: 3rd Floor 52 Jermyn Street, London SW1Y 6LX       
1.7 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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

1.8 This version was last updated on [DATE] May 2018, and historic versions are archived and may be obtained by contacting us.

1.9 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.

2 THE DATA WE COLLECT ABOUT YOU

2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
2.2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2.2.2 Contact Data includes billing address, delivery address, email address, log in details for Your Accounts and telephone numbers.
2.2.3 Medical Data includes details of your medical records, Your Advisers and information that you provide to us or any of Your Advisers or using any of Your Accounts.
2.2.4 Financial Data includes [bank account and payment card details].
2.2.5 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or Your Advisers that we or Your Advisers have delivered to you.
2.2.6 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or Your Accounts.
2.2.7 Profile Data includes your username and password for our web sites and Apps and Your Accounts, purchases or orders made by you, your interests, preferences, feedback and survey responses.
2.2.8 Usage Data includes information about how you use our website, products and services, Your Accounts and how you interact with Your Advisers.
2.2.9 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from many users’ (including your own) personal data but is processed and stored so that it is anonymous data and is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect 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 and stored in accordance with this privacy notice but shall not be shared.

2.4 Except to the extent necessary to provide services to you (and provided to us by you or Your Advisers) we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

2.5 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.  You will remain responsible for all costs incurred by us in our reasonably relying on you providing the relevant information.

3 HOW IS YOUR PERSONAL DATA COLLECTED?

3.1 We use different methods to collect data from and about you including through:
3.1.1 Direct interactions. You may give us personal information (including identity, medical, contact and financial data) by filling in forms, authorising your medical practitioner or otherwise by corresponding with us through electronic or other media (including by post, phone, email or otherwise). This includes personal data you provide when you (or your medical practitioner acting on your behalf):
3.1.1.1 apply for our products or services;
3.1.1.2 create an account on our website;
3.1.1.3  subscribe to our service or publications;
3.1.1.4  request marketing to be sent to you;
3.1.1.5  enter a competition, promotion or survey; or
3.1.1.6  give us feedback.
3.1.2  Automated technologies or interactions. As you interact with our website or apps or through Your Accounts or with Your Advisers , we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
3.1.3   Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
3.1.3.1 Technical Data from the following parties:
(a) Your Accounts;
(b) search and analytics providers, such as Google based outside the EU;
(c) promotional networks; and
(d) others
3.1.3.2 Contact, Financial and Transaction Data from Your Advisers and Your Accounts and providers of technical, payment and delivery services.
3.1.3.3 [ANY OTHER WAYS YOU COLLECT PERSONAL DATA?].

4 HOW WE USE YOUR PERSONAL DATA

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.2 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.
4.1.3 Where we need to comply with a legal or regulatory obligation.

4.2 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 us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

4.3 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4.4 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. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.