- The types of personal information we collect on the WELLE CLUB Platform and how we collect it;
- How we hold and use the information, including to provide promotional materials and advertisements that have been tailored to you based on the personal information provided;
- To whom we may share personal information;
- The choices available to you regarding our use of personal information;
- The measures we take to protect the security of information; and
- How you can contact us about our privacy practices.
1. COLLECTION OF PERSONAL INFORMATION
- first and last names, email address and date of birth;
- other information such as country of residence and gender, home address and telephone number;
- dietary preferences and data relating to your physical characteristics (e.g. weight, height and other body measurements to the extent you choose to enter these on the Platform);
- fitness activity data provided by you on the Platform or generated through your use of the WELLE CLUB App (e.g. time, duration, distance, location, calorie count), including activity data generated by the devices (e.g. smart watches, heart monitors) that you connect to the WELLE CLUB App;
- information you provide about yourself and any preferences in your User Account;
- information about your purchases of products and services from us or our third party partners who may provide or promote their own products or services through the Platform;
- information about your use of the Platform;
- communications with us or directed to us via letters, emails, chat services, calls, and social media;
- any content you voluntarily provide or contribute;
- your location where the IP address of your computer or device is used to determine your geographic location so that we can customise your experience on the Platform (e.g. language settings)
- We may ask for and collect personal information (either directly through your use of the Platform or when you communicate with us in any other way, or indirectly through our third party partners or providers)
- We may also collect information from you automatically when you visit our Platform.
2. USE OF PERSONAL INFORMATION
Personal information may be used to:
- Provide features on the Platform and products and services you request;
- Communicate information about our products and services and for other promotional purposes (from which you may opt-out);
- Carry out customer service communications;
- Carry out administrative or for legal purposes;
- Verify the information, and to prevent fraud or other unlawful activities. This includes sharing personal information with government authorities or enforcement bodies for compliance with legal requirements, or otherwise as required or permitted by applicable Data Privacy Law;
- Carry out anything else you give us informed consent to.
3. PROTECTION AND MANAGEMENT OF PERSONAL INFORMATION
3.1 Encryption and security
The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the internet.
3.2 International transfers of your Personal information
As an online platform, WELLE CLUB operates in multiple jurisdictions. The personal information that WELLE CLUB collects from users will be stored in New Zealand and might also be shared with third party data recipients (e.g. e-commerce and logistics providers and customer support providers) that are not located in New Zealand, the European Economic Area, Australia or the United States of America. Therefore, the personal information that you provide to WELLE CLUB may be transferred internationally to countries other than the country in which you initially provided your data.
3.3 Retention of your Personal information
We will not retain your data for longer than is necessary to fulfil the purposes for which it is being processed. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the purposes for which we process it, and whether we can achieve those purposes through other means.
We also consider the periods for which we might need to retain personal information in order to meet our legal obligations, or to deal with complaints and queries, and to protect our legal rights in the event of a claim being made.
In general, this means that we will likely keep your personal information for as long as your User Account is open. Following closure of your User Account, however, we may still retain a limited portion of your Personal information so that we can maintain a continuous relationship with you if and when we are in contact with you again, and to comply with our internal processes and any legal obligations.
When we no longer need your personal information, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal information that we use, and if we can anonymise your personal information so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
4. SHARING PERSONAL INFORMATION
- other companies and members within the WELLE CLUB group;
- our trusted third party partners (identified on our website), who may offer products and services on or through our Platform. You should consult their privacy policies for further information;
- third party social media platforms in various circumstances, including where:
- you are able to access third party social media services through our Platform or before coming to our Platform;
- you connect your User Account to your social media account, in which case we will receive from the social media platform the Personal information you choose to share, based on the preferences and settings on your social media account. We will use this information in order to improve and personalise your use of our Platform; and
- we use social media plugins on our Platform (e.g. a “share” or “like” button), and your use of these plug-ins, may result in the disclosure of certain of your information to the social media platform in question, and possibly presented on your social media profile, to be shared – with others in your network – however, we will only share your Personal information with these social media platforms if you have provided your express consent for us to do so.
- other companies, contractors or agents that assist us in providing services to you, including our online e-commerce platform that allows us to sell and deliver our products and services to you, support ticketing, legal services, debt collection, administration services, customer services and information technology support;
- only where you have provided consent, other companies, contractors or agents in connection with our marketing efforts, or marketing platform providers;
- government authorities, law enforcement bodies and regulators for compliance with legal requirements, or where otherwise required by applicable Data Privacy Law; and
- our legal and other professional advisers in order to enforce our legal rights in relation to our contract with you.
We may also transfer your Personal information to potential buyers in the event that we sell or transfer all of a part of our business or assets (including in the event of a reorganization or dissolution / liquidation), under strict non-disclosure restrictions, and solely in order to allow a buyer to determine whether to proceed with the transaction, or where such a determination is made, to complete it.
5. YOUR RIGHTS AND CHOICES
Under applicable Data Privacy Law you may have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it;
- Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing;
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes;
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you;
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
If you wish to exercise your rights related to your Personal information (including the rights set out above), please contact the WELLE CLUB team using the details above.
While you will generally not be required to pay a fee to access your Personal information or to exercise any of your other statutory rights, we may charge a reasonable fee if your request for access is unfounded or excessive or decline to comply with such requests where permitted by applicable Data Privacy Law.
You also have the right to lodge a complaint about our processing of your Personal information with the body regulating data protection in the country or state / province in which you live.
If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your Personal information, please contact the WELLE CLUB team at the following email address: email@example.com.
WELLE CLUB Limited (NZBN 942904877137) (referred to as WELLE CLUB, we, us, or our) is the data controller for all personal information that is collected and used for the purposes of data privacy laws, principles and regulations which may apply (including the European General Data Protection Regulation “GDPR”) (collectively, “Data Privacy Law”).