Privacy Policy

Privacy Notice of Rosewater Wellness Ltd trading as Wellbeing Centre for Learning

1. Introduction

1.1 This Privacy Notice is provided by Rosewater Wellness Ltd (a company limited by shares which is incorporated in England and Wales and registered with company number 12685830) whose registered office is Hollinwood Business Centre, Albert Street, Oldham, United Kingdom, OL8 3QL and which trades as “Wellbeing Centre for Learning”(plus such other potential trading names as may be used from time to time) (referred to as we, us or our.

1.2 We respect your privacy and are committed to protecting your personal data.

1.3 This Privacy Notice is intended to inform you as to how we look after your personal data however you interact with us (including via our website(s) , social media platforms-and -regardless of where you visit any of them from) and to tell you about your privacy rights and how the law protects you.

2 Definitions

2.1 The following definitions and terminology apply to these Terms and Conditions, Privacy Statement and Disclaimer Notice and any or all Agreements:

“The Company” “Ourselves”, “The membership”, “We” and “Us”
refers to Rosewater Wellness Ltd (trading as Wellbeing Centre for Learning) is registered in England and Wales (registered company no. 12685830) of Hollinwood Business Centre, Albert Street, Oldham, United Kingdom, OL8 3QL

“Party”, “Parties”, or “Us”
refers to both the Customer and ourselves, or either the Customer or ourselves. All terms refer to the offer, acceptance and consideration of payment necessary to undertake the process of our assistance to the Customer in the most appropriate manner, whether by formal meetings of a fixed duration, or any other means, for the express purpose of meeting the Customer’s needs in respect of provision of the Company’s stated services/products, in accordance with and subject to, prevailing English Law. Any use of the above terminology or other words in the singular

“Customer”, “Member”, “You” and “Your”
refers to you, the person accessing this website and accepting the Company’s terms and conditions.

“Our site” or “Our Website”
The “Wellbeing Centre for Learning” website and / or any associated site(s)

“Consumer”
is an individual that is buying products from us wholly or mainly for your personal use. (i.e. not for use in connection with your trade, business, craft or profession)

“Data Protection Laws”
means the Data Protection Act 1998, the General Data Protection Regulation (EU 2016/679) or any applicable statutory or regulatory provisions in force from time to time relating to the protection and transfer of personal data;

“Legitimate Interest”
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract”
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation”
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

“Internal Third Parties”
Other companies in our group of companies (from time to time) based (including those who may be acting as joint controllers or processors).

“External Third Parties”
Service providers (such as those who provide IT and system administration services).

Professional advisers and assistance service providers (including lawyers, bankers, accountants, auditors, insurers and consultants).

HM Revenue & Customs, regulators and certain other public authorities

Certain other third parties, for example, market researchers, fraud prevention agencies, price comparison sites etc.

“Request access”
to your personal data (commonly known as a “data subject access request”). 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 such 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 scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.

2.2 Unless the context requires otherwise, references to the singular include the plural and the masculine includes the feminine and vice versa.

2.3 Capitalisation and/or he/she or they, are taken as interchangeable and therefore as referring to same.

2.4 The headings contained in these Terms are for convenience only and do not affect their interpretation.

3 Important Information

3.1 The purpose of this Privacy Notice is to give you information on how we collect and process your personal data, including any data you may provide through use of our website(s) and/ or social media platforms. including any data you may provide through use of our website(s) when you purchase a product or service (or sign up to any of our newsletter(s), or take part in a competition).

3.2 Our website(s) and social media platforms are not intended for children and we do not knowingly collect data relating to children.

3.3 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.

3.4 This Privacy Notice supplements the other notices and is not intended to override them.

3.5 We are the controller and responsible for your personal data.

3.6 We have appointed one of our Director’s (or another appropriate senior member of staff) to be our data protection officer (DPO). They are responsible for overseeing questions in relation to this Privacy Notice.

3.7 If you have any questions about this Privacy Notice, including any requests to exercise your rights, please contact our DPO using the contact details as set out (from time to time) upon the web-page:- https://wellbeingcentreforlearning.com/contact – such details including – by an email sent to: -info@wellbeingcentreforlearning.com

3.8 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).

3.9 We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3.10 Our Privacy Notice has been updated by reference UK data protection law changes arising pursuant to the General Data Protection Regulation (GDPR), which came into force on Friday, 25th May 2018.

3.11 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.

3.12 Our website(s) and/or social media platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our website(s) and /or social media platforms, we encourage you to read the Privacy Notice of every website that you visit.

4 The Data we collect about you

4.1 Personal data, or personal information, means any information about an individual from which that person can be identified.

4.2 It does not include data where the identity has been removed (anonymous data).

4.3 We may collect, use, store and transfer different kinds of personal data about you – which we have grouped together as follows:

a. Identity Data including first name, last name, marital status, title, date of birth and gender.

b. Contact Data including billing address, delivery address, email address and telephone number.

c. Financial Data including bank account, payment card and electronic payment details.

d. Transaction Data including details about payments to and from you and other details of products and services that you have purchased from us.

e. Technical Data including data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

f. Profile Data including your username and password, your interests, preferences, feedback and survey responses.

g. User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

h. Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media platforms and messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

i. Marketing and Communications Data which includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

k. We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but 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 in accordance with this privacy notice.

4.4 Sensitive Data, we often carry out surveys and quizzes to better understand you (our audience), so we can help you to build a successful business and/or choose the right services and products for you. Some of the questions we ask may provide us with sensitive data about you. We will also collect sensitive data from you if you join our membership. We require your explicit consent for processing sensitive data.

4.5 Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

4.6 We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@wellbeingcentreforlearning.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.

5 How is your personal data collected?

5.1 We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a. apply for our products or services;

b. create an account on any of our website(s);

c. subscribe to our service or publications

d. request marketing to be sent to you;

e. enter a competition, promotion or survey; or

f. give us some feedback.

5.12 Automated technologies or interactions. As you interact with any of our website(s) and /or social media, 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

5.13 Third parties or publicly available sources. We may receive personal data about you from various third parties (and public sources) based both inside and / or outside the EU – such as those as are set out below:

a. Technical Data from the following parties:

b. analytics providers;

c. advertising networks; and

d. search information providers.

e. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

f. Identity and Contact Data from data brokers or aggregators.

g. Identity and Contact Data from publicly availably sources.

6 How we use your personal data

6.1 We will only use your personal data, when the law allows us to.

6.2 Most commonly, we will use your personal data in the following circumstances:

a. Where we need to perform the contract, we are about to enter into or have entered into with you.

b. 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.

c. Where we need to comply with a legal or regulatory obligation.

6.3 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 electronic text message. You have the right to withdraw consent to marketing at any time by contacting us.

6.4 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.

6.5 Please 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity(b) Contact	Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity(b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products / services, to develop them and grow our business)
To administer and protect our business and our website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website(s), products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website(s) updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products / services and grow our business)

6.6 Marketing as we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may establish a privacy centre where you can view and make certain decisions about your personal data use or the following personal data control mechanisms:

6.7 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).

6.8 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us (or if you provided us with your details when you entered a competition or registered for a promotion) and, in each case, you have not opted out of receiving that marketing.

6.9 Third-party marketing, we will get your express opt-in consent before we share your personal data with any company outside of us (or our group of companies) for marketing purposes.

6.10 Opting out, you can ask us (or third parties) to stop sending you marketing messages at any time by

6.11 accessing any privacy centre accessible from our website(s) and checking or unchecking relevant boxes to adjust your marketing preferences; or

6.12 by following the opt-out links on any marketing message sent to you; or

6.13 by contacting us (at any time).

6.14 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

6.15 Cookies, you can set your browser to refuse all (or some) browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website(s) may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

6.16 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 obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

6.17 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.

6.18 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 law.

7 Marketing Communications

7.1 Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

7.2 Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from us at any time.

7.3 You can ask us to stop sending you marketing messages at any time by clicking on the unsubscribe link and the bottom of our emails.

7.4 If you opt-out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

8 Disclosures of your personal data

8.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

a. Internal Third Parties (within the meaning – as set out in the Glossary below).

b. External Third Parties (Ditto).

c. 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.

8.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

9 International Transfers

9.1 We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

9.2 Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

9.3 Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

9.4 Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

9.5 We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

9.6 Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

9.7 If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

9.8 If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

10 Credit Card Data

10.1 We do not collect or store your full credit card information when you make a payment online. All credit card transactions are processed securely through PayPal and or Stripe, and at no point does the Female Entrepreneur Association receive your full credit card information or store this. Therefore, your card information is completely secure and protected by PayPal and or Stripe and none of our employees have any access to your full credit card number, payment platform profile or security code whatsoever.

11 Data Security

11.1 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.

11.2 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.

12 Data Retention

12.1 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 reporting requirements.

12.2 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.

12.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers (for tax purposes).

12.4 In some circumstances you can ask us to delete your data: see ‘Request erasure’ in the Glossary set out below for further information.

12.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes – in which case we may use this information indefinitely without further notice to you.

13 Your Legal Rights

13.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary set out below to find out more about these rights.

13.2 If you wish to exercise any of the rights set out in the Glossary, please contact us.

13.3 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 such circumstances.

13.4 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.

13.5 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.