Privacy

Policy

1. INTRODUCTION

 

This is the Privacy Policy of Talking Wellbeing LIMITED  (hereinafter: “TW”, “we” or “us”). Properly handling  your personal data is extremely important to us. Subsequently, we take a diligent approach to protecting and processing your personal data. This is done in accordance with international privacy laws (including the General Data Protection Regulation).


This Privacy Policy covers the ways in which we protect and respect your right to privacy. We advise you to read this Policy carefully, as It covers the way in which we use your personal data when you use our services, access our website and interact with us through different communication channels. 

 

Please read the following carefully to understand our ethos when handling your personal data.

2. PERSONAL DATA

The following bullet points detail the personal data that we collect about you when you use our services use our  (hereinafter jointly referred to as: “Personal Data”): 

  • Contact Details. Your name, your location and telephone number, such as your telephone number and e-mail address, and any other contact details you provide to us. 

  • Your electronic identification data and other information are automatically collected when you visit our website, by navigating (opening, clicking, reading, cursor-movement etc.) with our newsletter or being exposed to Talking Wellbeing's online marketing advertisements. We automatically collect data through your browser or device, through the use of cookies and other technology to track visitors on the Talking Wellbeing website (including web analytics), such as your IP address, browsing behaviour, MAC address. You learn more about this information by viewing our Cookie Policy 

  • Your online purchases. To complete your online purchases via the Talking Wellbeing official website we use your name, telephone number, contact details and other relevant information regarding your purchases, such as the amount and date of your purchases, the service that you purchase, the device used to complete your purchase, your payment method, payment status, bank account details, delivery method and in cases of services which require us to travel to a location delivery address.

  • Your data when subscribing to our newsletter. To be able to provide you with the Talking Wellbeing newsletter which contains motivational and commercial content, we use your email address and additional information if you add such to your profile, such as name, and date of birth. Talking Wellbeing may also send out tailored newsletters which reflect your personal preferences if you have chosen to provide Talking Wellbeing with those.

  • Your communication data. This refers to any such data shared by you when communicating with us via telephone, social media, online, social media or any other form, for example queries, complaints or requests.

  • Your feedback and reviews. The opinions, experiences, and service event reviews that you  share with us online or publish on our website.

3. PURPOSES OF PERSONAL DATA USE 

The Personal Data we collect is solely used for the following purposes:

For our legitimate business interests: We use your Personal Data (as described above) for the purpose of advertising Talking Wellbeing Services, to contact you via e-mail, social media and other means for legitimate business purposes. Additionally, we also use your Personal Data for analysis which helps us to improve our Services. This analysis allows us to rationally evaluate what may interest you, and how to tailor our advertising to you. Additionally, depending on your previous purchases of Talking Wellbeing Services, we may target you with advertisement or other marketing materials that are tailored to your personal preferences. 

 

For the performance of our agreement with you: So that we can efficiently carry out our obligations regarding any contractual agreements entered into between you and Talking Wellbeing, and to provide you with any services and information that you request, including managing and handling your enquiries, questions and complaints. This also includes enabling you to purchase our services by responding to your requests to provide effective customer service, by providing you with information about our services and to enable us to respond to your queries, and any other request made on your behalf. 

We may also use your Personal Data, for our other legitimate business interests for example in instances of developing or changing our services, to improve the efficiency of our business activities;  to create accumulated statistics about the users of Talking Wellbeing Services; to facilitate our business operations; ; to allow us to make corporate transactions, for example any sale, restructure, transfer of Talking Wellbeing assets , bankruptcy, acquisition or similar occurrence or for other legitimate business purposes permitted by applicable law. 


Use of information based on your consent: 
If you haven’t purchased any Product or service from us, we will only send you direct marketing communications (such as newsletters, promotions, news on products or service updates) via email, other electronic means, via telephone or via hardcopy mail (such as flyers), after we have received your consent to do so. 

We use your health data for the purposes set out in this Privacy Policy but we will only do so after we have received your consent thereto. 

Children under the age of 16 cannot legally give their consent. Instead, consent of their parent or legal guardian needs to be provided. 

You can withdraw your consent at any time (see the section Your rights below). 
To comply with our legal obligations: Any Personal Data we collect may be used to comply with a legal obligation to which we are subject, such as supervisory bodies, fiscal authorities or investigation bodies. 

4. SOCIAL MEDIA

When you participate in various social media forums like Facebook, Twitter, Instagram, LinkedIn, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the personal data in your social media profile(s).

 

Talking Wellbeing is bound by the privacy practices or policies of these third parties, so we encourage you to read the applicable privacy notices, terms of use and related information about how your personal data is used in these social media environments. 

 

Also, depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the Talking Wellbeing pages), certain personal data may be shared with Talking Wellbeing about your online activities and social media profiles (e.g. interests, marital status, gender, user name, photo, comments and content you have posted/shared etc.).

5. SHARING YOUR PERSONAL DATA

We share your Personal Data with the following parties: 
 

  • Third Party suppliers. We engage third parties, from time to time, to help us providing us our Products and Services, including:
     

    - Business partners, suppliers (such as IT service providers) and sub-contractors; 

    - Contact centers, to assist us on the Consumer Service-department;

    - Advertising and media companies that carry out marketing and media activities on our behalf; 

    - Analytics and search engine providers that assist us in the improvement and optimisation of our website and apps, such as Google Analytics. 


    In providing their services, they will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require such Third Party suppliers to adequately safeguard your Personal Data and only process it in accordance with our instructions. 

  • Third parties in case of legal requirement. We may also disclose your Personal Data if we believe we are required to do so by law.

  • With consent. We may also disclose information about you, including Personal Data to any other third party, where you have consented or requested that we do so, for example in case of a promotional campaign with another sponsor.

6. SECURITY

We will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss. 

 

We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Policy. Furthermore, we contractually ensure that any Third Party supplier processing your Personal Data equally provide for confidentiality and integrity of your data in a secure way.

7. DATA RETENTION

We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim.

8. YOUR RIGHTS

Subject to the conditions set forth in the applicable law, you have the the following rights with regard to our processing of your Personal Data: 

 

  • Right of access – You have the right to request confirmation if Talking Wellbeing processes personal data about you, and if such is the case, access to the personal data and additional information. Upon request, we can also provide you with a copy of the personal data undergoing processing;

  •  

  • Right to rectification – You have the right to request that Talking Wellbeing corrects, adjusts or completes your Personal Data if we have inaccurate or incomplete data relating to you. You can also correct, adjust or complete your personal data yourself by updating your profile. We also kindly request you to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to Talking Wellbeing so that we can ensure that your Personal Data is up-to-date. Talking Wellbeing will take all reasonable steps to ensure that all Personal Data are correct;

  •  

  • Right to withdraw consent – You have the right to revoke your consent for receiving marketing communications at any time, by following the instructions in any marketing communication or by filling in the form as set out below. If we use your Personal Data based on your consent for other reasons than marketing communication, you can revoke your consent by filling the form as set out below;

  •  

  • Right to delete - You have the right to request deletion of any irrelevant Personal Data we hold about you when (i) the data is no longer necessary in relation to the purposes for which they are collected; (ii) you withdraw your consent and there is no other legal ground for processing; (iii) you object to the processing in case of direct marketing purposes, or – in any other case - there is no overriding legitimate ground for processing; (iv) we unlawfully processed your data. If you have such a request and all requirements are met, we shall make sure that Talking Wellbeing erases the data of which we are not under a legal obligation to retain;

  •  

  • Right to restriction of data use - You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but you require them for the establishment, exercise or defence of legal claims; or (iv) you have objected to data use justified on our legitimate interests pending verification as to whether Talking Wellbeing has indeed compelling interests to continue the relevant data use;

  •  

  • Right to data portability - to the extent that we use your Personal Data for the performance of an agreement with you, and that personal data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to Talking Wellbeing in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible;

  •  

  • Right to object - to the extent that we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. You also have the right to object to profiling activities conducted by Talking Wellbeing;

  •  

  • Right to lodge a complaint - You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Policy or applicable law.

  •  

For further information regarding your rights, or to exercise any of your rights, please complete this contact form, and do the following:

 

  • Select the option ’privacy request’ under “Choose subject”; and

  • Select the relevant subcategory; and

  • fill in all the e-mail address(es) that you use and have used for all related Talking Wellbeing services in the comment box, such as but not limited to registration newsletter, account for the webshop, app for the Wireless Perfume Diffuser etc.; and

  • upload a blacklined copy of your identity card/passport, of which you have blacklined all information that is not required to be able to identify you, which is everything except your first name and last name. To be more precise, please blackline the following information:

- Social security number (please note that in some identity cards/passports this is stated on 2 different places);
- Document number; 
- Nationality; 
- Date of birth; 
- Place of birth; 
- Height; 
- Date of issue; 
- Expiry date; 


Upon receipt of all the information as set out above we shall respond to your request consistent with applicable law.