About this Privacy Policy

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At Wellness By Sorangel, we are committed to protecting and respecting your privacy.

We want to give you the best service possible. In order to achieve this, when you interact with us be it in our deli, on our website, within our app or when you subscribe to our newsletter, we will gather information on you in order to improve these interactions. Some of this data you will formally give us like your email address and other information may be anonymously gathered.

The following Privacy Policy details information on when and why we collect your personal data, how we use it, the limited conditions under which we may disclose it to others and how we keep it secure.

Please read the following carefully to understand how we collect and process your personal data.

This covers, without limitation, your interaction with and use of our Wellness By Sorangel website, wellnessbysorangel.com, and any component element or part of that website, including the Wellness By Sorangel app, our Webshop, our Newsletter and any of our other Services, whether interacting with and/or using our Services as a consumer or while in the course of work or in any other business or enterprise capacity, context or environment.

By using our website, app or other properties you consent to the collection and use of the information you provide to us, as outlined in this Privacy Policy.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy 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 Policy supplements other notices and privacy policies and is not intended to override them.

Changes to this Privacy Policy and your duty to keep us informed

We keep our Privacy Policy under regular review. If we make changes to this Privacy Policy, we will publish the changes on this page and let you know by email or through your account details of these changes.

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.

Our details and how to contact us

 

 

If you have any questions or concerns about our collection, use or disclosure of your personal information, please contact us at namaste@wellnessbysorangel.com.

Collection and use of personal data

Personal data means any information that may be used to identify you, such as your name, title, phone number, email address, or postal address. It is information where you as an individual can be identified. It does not include data where your identity has been removed.

We may collect, use, store and transfer different kinds of personal data about you including:

• your name, address and contact information, including email address and telephone number and company details;

• any delivery addresses specified for your order;

• information to check and verify your identity, e.g. date of birth;

• your gender, if you choose to give this to us;

• location data, if you choose to give this to us;

• your billing information, transaction and payment card or other payment method information;

• bank account and payment details;

• details of any information, feedback or other matters you give to us by phone, email, post or via social media;

• your account details, such as username and login details;

• your activities on, and use of, our website and app;

• information about the services we provide to you;

• information about how you use our website and technology systems;

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website and/or app or any services we provide.

We do not knowingly collect special categories of data (also known as sensitive personal data). If we were to do so, we would do so on the basis that it was necessary for reasons of substantial public interest, to establish, exercise or defend any legal claims, or in some cases, with explicit consent. In any case, we would carry out the processing in accordance with applicable laws.

How your personal data is collected

We collect personal data from you in the following ways:

• Your interaction with us: We shall collect your personal data where you register an account with us, either through our website or the app, when you purchase products and/or services from us, complete surveys or provide feedback. We may also collect certain personal data if you interact with us on social media.

• When browsing our website: In general, you can browse the Wellness By Sorangel website without giving us any personal information. We use several products to analyse traffic to our website in order to understand our visitors’ needs and to continually improve our website for them, such as Google Analytics. We collect only anonymous, aggregate statistics. There are some services on our website that require you to be registered. For example, to receive our newsletter or purchase products from our online store. As part of the registration process, we collect your personal data. We use this information to send you newsletters if you’ve opted-in to receive them, and to fulfil orders from our shop. We will never sell, rent or trade email lists with other companies and businesses for marketing purposes.

• In our Restaurant: In our Restaurant, you can log onto our free Wi-Fi. In doing so, you will be asked to share some personal data with us. The provider of this service is a third party which does hold personal data about you when you log onto the free Wi-Fi, such as your email address and location of where you logged in. This data is held for internal use only, for example we have previously emailed Wi-Fi users an email regarding Restaurant events (which can be unsubscribed from upon receipt). This information is not shared with any other third parties.

• Through third parties or publically available sources: We may receive personal data from the following sources:
  Social media: We use social media and other similar platforms such as Instagram or Facebook to interact with our customers. When this happens you will have a direct relationship with these platforms and agree to their terms of use. We only have information that you have agreed for us to access through these platforms. We are not responsible for these platforms and how they manage your personal data. Should you have any privacy related questions please contact them. If you have any questions about our social media activity please contact ushere.
  Health apps: Our Wellness By Sorangel app makes use of the Apple Health App (“HealthKit”). You can choose to connect and share information with HealthKit and your HealthKit information with any of our app. If you grant our app access to HealthKit, our app can add information such as calories, protein, fat, carbohydrates, amongst other data, to HealthKit. Your unique health data you choose to send to and from HealthKit (including age, gender, weight) is not accessible by us and is not transferred by us to any third parties. Our app cannot write data to HealthKit unless you grant access. You can remove access at any time either inside our app or inside the Apple Health app. We are in no way responsible for the protection of any of your information that you agree to store with HealthKit, which is governed by Apple’s privacy policy and other terms. You and Apple are solely responsible for the protection of such information. Please review Apple’s applicable policies and procedures before syncing and backing up your health data and/or other information with the Health Kit.

Links to third party websites

Our website contains links to information on other websites, for example, a guest blog post may link to the guest blogger’s website. On websites we do not control, we cannot be responsible for the protection and privacy of any information that you provide while visiting those sites. Those sites are not governed by this Privacy Policy, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy notice.

How and why we use your personal data

Under data protection laws, we can only use your personal data if we have a lawful reason to do so e.g:

• where you have given your consent;

• to comply with our legal and regulatory obligations;

• for the performance of a contract with you or to take steps at your request before entering a contract; or

• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us.

Please see the table below which explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Creating and managing your account with us.

To perform our contract with you or take steps at your request before entering into a contract.

Providing products to you including providing information to third party providers e.g. financial services or delivery providers.

To perform our contract with you or take steps at your request before entering into a contract.

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us.

To comply with our legal and regulatory obligations.

To meet our internal and external audit requirements, including our information security obligations.

To comply with our legal and regulatory obligations.

Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of the website.

Depending on the circumstances:

• your consent as obtained e.g. by the separate cookies tool on our website. See Cookies section below for further information.

• where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended.

Depending on the circumstances:

• your consent as obtained e.g. by the separate cookies tool on our website. See Cookies section below for further information.

• where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices.

Depending on the circumstances:

• to comply with our legal and regulatory obligations.

• in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.

Protecting the security of systems and data used to provide the services.

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us understand our customer base.

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.

Updating and enhancing customer records.

To perform our contract with you or to take steps at your request before entering into a contract.

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business

To comply with our legal and regulatory obligations.

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

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.

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.

Marketing

You can subscribe to our newsletters and marketing materials though our app, website and other channels and this includes entering competitions through, or subscribing to in to receive information from us through other channels.

We will use your personal data to send you the newsletters and marketing materials (either by email, text message, telephone or post). We may also send you updates on our products including exclusive offers, promotions and new products.

We have legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by clicking the unsubscribe link at the bottom of any of our newsletter emails or by contacting our Customer Support Team.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy .

Who we share your personal data with

To provide our services to you, we may share your personal data with:

• any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time, as defined in section 1159 of the UK Companies Act 2006.

• third-party service providers who provide IT, sales, marketing and system administration services.

• our external auditors and/or professional advisers, in which case the third party recipient of the information will be bound by confidentiality obligations.

We may aggregate and anonymise your Data and share with selected third parties in accordance with this Privacy Policy.

In rare cases we may disclose your personal information:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• if Wellness By Sorangel or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements.

• to protect the rights, property, or safety of Wellness By Sorangel, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data and how we keep it secure

Some personal data that we collect from you may be stored and processed outside the EEA by our service providers based in the USA who provide IT, sales, marketing and system administration services (all of whom are Privacy Shield certified).

For webshop orders your personal data required to make the order delivery will be shared with our third party fulfilment partner and with their delivery partner Royal Mail both based in the EEA.

Countries where personal data relating to you may be stored and/or processed, or where recipients of personal data relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence. By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We take measures to ensure that any international transfer of information is managed carefully and in accordance with data protection law to protect your rights and interests and in accordance with this Privacy Policy.

These measures include:

• transfers of your personal data to countries which are recognised as providing an adequate level of legal protection for personal data;

• we have obtained the consent of data subjects to the international transfer of their personal data;

• transfers to organisations where we are satisfied about their data privacy and security standards and protected by contractual commitments such as signing the Standard Contractual Clauses and, where available, further assurances such as certification schemes.

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.

Where we have given you (or where you have chosen) a password which enables you to access Wellness By Sorangel, you are responsible for keeping this password confidential. You must not to share a password with anyone.

You have the right to ask us for more information about our safeguards. Please contact us if you would like to receive further details.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to Wellness By Sorangel; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long we keep your personal data

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. We will delete your personal data within 30 days if you delete your account.

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.

Your Legal Rights

You have certain rights regarding your personal data. These include the rights to:

request a copy of the personal data we hold about you;

• request that we supply you (or a nominated third party) with an electronic copy of the personal data that you have provided us with;

• inform us of a correction to your personal data;

• exercise your right to restrict our use of your personal data;

• exercise your right to erase your personal data; or

• object to particular ways in which we are using your personal data (such as automated decision making, or profiling (for example to help us decide what products and services would suit you best); or

• understand the basis of international transfers of your personal data by us.

Where we rely on our legitimate interests to obtain and use your personal data then you have the right to object if you believe your fundamental rights and freedoms outweigh our legitimate interests. Where processing is carried out based upon your consent, you have the right to withdraw that consent.

Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular personal data we hold on you.

You should note that if you exercise certain of these rights we may be unable to continue to provide some or all of our products or services to you (for example where the personal data is required by us to comply with a statutory requirement, or is necessary in order for us to perform our contract with you).

We ask that you contact us to update or correct your personal data if it changes or if the personal information we hold about you is inaccurate.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.