Liberty Wellness Ltd respects the privacy of everyone who visits this website, www.libertywellness.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. We intend to give you as much control as possible over your personal information. In general, you can visit this Site without telling us who you are or revealing any information about yourself. However, we collect technical information, such as an IP address and your browser information in order to make a connection and display our website. For example, we might collect data regarding your journey through the website or record the options that you have chosen to select. This is a common standard procedure for any website on the Internet. The information collected does not directly identify you but may be helpful to us for marketing purposes and improving the services we offer.
There are times, however, when we collect information directly from you, such as your name and address; for example, when you fill out a form to request information about Herbalife products or Herbalife membership, or to establish contact with a member or to participate in a challenge or sweepstake. On those occasions, we may provide you additional information and choices about our intended use of your personal information, if required. We also collect your communication preferences, such as whether or not you wish to receive commercial e-mails.
Definitions And Interpretation
In this Policy the following terms shall have the following meanings:
Information About Us
Our Site is owned and operated by Liberty Wellness Ltd, a Private Limited Company registered in Scotland under company number SC451682.
Festival Business Centre, F14, 150 Brand Street Glasgow, G511DH
Data Protection Officer: David Christie
Email address: David@libertywellness.co.uk
Telephone number: 07974 654649
Postal Address: Festival Business Centre, F14, 150 Brand Street Glasgow, G511DH
What This Policy Covers
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Your Rights Under GDPR
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. We tell you how to do this below.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the contact details below to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the contact details below to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the contact details provided below.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
The Data That We Collect
- Date of birth;
- Email address;
- Telephone number;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system and device;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
How We Use Your Personal Data
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products or services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or other communication that you have opted-in to (you may unsubscribe or opt-out at any time by emailing firstname.lastname@example.org).
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We may use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the contact details below.
- The following automated decision-making and automated profiling method(s) may be used:
- Email marketing.
- Pay per click targeting.
How Long We Keep Your Personal Data
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will, therefore, be kept for reasonable periods determined by the likelihood of your continued intention to contract with our business or be interested in our products or services.
How and Where We Store or Transfer Your Personal Data
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We use specific contracts with external third parties that are showing to be compliant with GDPR for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
Sharing Your Personal Data
We may share your personal data with other companies in our group for the same purposes as described in this policy. This includes subsidiaries or our holding company and its subsidiaries.
We may sometimes contract with the third parties to supply certain products or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. A list of these third parties can be provided at any time by contacting as us described below.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described immediately above.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Controlling Your Personal Data
In addition to your rights under the GDPR, set out above, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
Accessing Your Personal Data
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown below.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for marketing and apps which are used to improve the functionality of our website. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are available upon request using the contact details provided below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by hosting providers and Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the product and services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of our Data Protection Officer: David Christie
Email address: David@libertywellness.co.uk
Telephone number: 07974 654649
Postal Address: Festival Business Centre, F14, 150 Brand Street Glasgow, G511DH
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.