1. Introduction

 

Privacy and personal information are very important to Oolong Limited, and we take it seriously. We have a mission to facilitate safe, secure, and trustworthy coaching services. Doing so requires a commitment to the privacy of our community.

 

Oolong Limited (referred to as “We, “Our” or “Us”), is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of our customers and users of our service that communicate (online or offline) with us, over the phone, through our mobile application, websites and social media platforms.

 

We have therefore developed this privacy policy to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

 

Throughout this document we refer to Data Protection Legislation which means the Data Protection Act 2018, GDPR (United Kingdom General Data Protection Regulation) (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people of the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time. Oolong Limited is the controller for the personal information we process, unless otherwise stated.

 

We are registered with the Information Commissioner’s Office (the ICO) with registration number ZB271818

 

You can contact us either by phone, email or post.

 

Our main trading/postal address: Profile West, Suite 2 First Floor, 950 Great West Road, Brentford, United Kingdom, TW8 9ES

 

Email: help@avid.health

 

Our Data Protection Officer is: Dataguard, address: DataCo International UK Limited, Suite 1, 7th Floor, 50 Broadway, London, SW1H 0BL Email address: privacy@dataguard.co.uk

 

 

 2. The information we collect and when

 

We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Legislation. The type of personal information that we will collect on you, and you voluntarily provide to us on this website and as part of our service may include some or all of the following:

 

•  Your name

•  Email address

•  IP address

 

We may, in further dealings with you, extend this personal information to include the following:

 

• Identifiers including your age, address, phone

• Special category health and ethnicity data including gender, ethnicity, health and wellness information, self assessment and feedback data and results

• Inferences including personal information about your goals and aspirations for Oolong  Limited Services, or inferences derived from that information.

• Credit card and payment information collected when you purchase Services

• In connection with your participation in Services, we collect wellness and health data as necessary received through direct or indirect communication, self assessment data and results, such as information you input or provide when using Services, taking self assessment forms, providing feedback on progress related to and quality of Services, and the like.

• Additional data that may be collected in connection with your participation in the services includes:

  • Photos of Food: As part of the food log feature, we collect images of food uploaded by the user, along with a description, the time of eating, and the type of food. This information is shared with the user's health coach to inform care and enhance the user experience.

  • Body Measurements: We collect user inputted data on body weight and waist circumference.

  • Additional Health Data: We collect health data through clinical scoring systems and surveys. This data is used to improve the coaching experience, assess user progress, and evaluate the impact of our services.

• For those considering working with Oolong Limited, professional data and education information such as resume, employment history, qualifications, and position sought as applicable. 

• Information requested or required by regulatory or governmental authorities or law enforcement bodies. 

• Behavioral and marketing information such as your interests, and your public social media presence.

 

If you are not a member, you are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we require at least  the information above in order for us to deal with you as a prospective client or coach (service user) in an efficient and effective manner.

 

Where you are not a current or prospective service user, or website visitor, the legal basis for processing your data is based on your specific consent that we will have requested at the point the information was initially provided, therefore we will not store, process or transfer your data unless we have an appropriate lawful reason to do so. Where you are a member, the legal basis for processing your data is based on your performance of a contract that we will have stated at the point the information was initially provided, therefore we will not store, process, or transfer your data unless we have an appropriate lawful reason to do so.

 

We may in some circumstances, collect your personal data based on our legitimate interest, where our interest will not override your individual rights and freedoms. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

 

• Your consent. You are able to remove your consent at any time. You can do this by contacting help@avid.health

• We have a contractual obligation.

• We have a legal obligation.

• We have a legitimate interest.

 

 3. How we use your information

 

We collect Personal Information from and about you to:

 

• Set up your account, correspond with you, and otherwise enable and facilitate your usage of our Services or as is necessary for your use of and the provision of the Services.

• Assess eligibility and suitability for participation in our Services.

• Comply with applicable laws and regulations.

• Setup and maintain accounts to facilitate your payment for our services.

• Create and maintain your account profile.

• Provide you with information about, and solicit your further participation in, the Services (which may include research and development purposes).

• Provide you with the Services that you request from Oolong Limited.

• Study, test, and improve the Services, and the overall user experience and personal growth outcomes associated with using the Services.

• Offer customer support, technical support, maintenance, and product development.

• Protect against fraud, Site misuse, privacy, and security breaches.

 

 4. Who we might share your information with

 

We may share your personal data with other organizations in the following circumstances:

 

• If the law or a public authority says we must share the personal data;

• If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or

• From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Service.

 

However, all the information we share will be collected and anonymized, so neither you nor any of your devices can be identified from it.

 

We may disclose Personal Information that we have collected with our affiliates and third parties (whether located within or outside your jurisdiction) for the purposes described above. This includes:

 

• Any affiliate, adviser, contractor, agent or third party service provider (including but not limited to affiliated coaches and payment providers) who provide us with services relating to administration, telecommunications, payment, compliance, operations, customer service, information technology, records and data storage, performance measurement and compilation and analysis in connection with our provision of the Site and Services and our operations.

• Our service providers who provide us with security, fraud prevention, marketing technology, information technology, site analytics, site maintenance, software development, electronic signatures, identity verification and other features to provide Services, provided that all such parties will be under confidentiality duties to protect and not share any Personal Information we give them.

• To third parties you agree or ask us to disclose Personal Information.

 

We will not share your information with any third parties for the purposes of direct marketing.

 

We use data processors who are third parties who provide elements of services for us. We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us or further sub processors who must comply with our Data Processor Agreement. They will hold your personal data securely and retain it for the period we instruct.

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5. How we keep you updated on our products and services

 

We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously consented to receive these marketing communications. When you register with us, we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.

 

If you wish to amend your marketing preferences, you can do so by contacting us help@avid.health

 

6. Your rights over your information

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6.1 Right to be informed about our collection and use of personal data

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through our external website policy. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

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6.2 Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 30 days from when your identity has been confirmed.

 

We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If you would like to exercise this right, please contact us as set out below.

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6.3 Right to Correction Your Personal Information

If any of the personal information we hold about you is inaccurate, incomplete or out of date, you may ask us to correct it. If you would like to exercise this right, please contact us as set out below.

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6.4 Right to Stop or Limit Our Processing of Your Data

You have the right to object to us processing your personal information for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances. If you would like to exercise this right, please contact us as set out below.

 

 6.5 Right to Erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. If you would like to exercise this right, please contact us as set out below.

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6.6 Right to Portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used and machinereadable format. It also gives you the right to request that a controller transmits this data directly to another controller. If you would like to exercise this right, please contact us as set out below.

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6.7 Right to object

You have the right to object to our processing of some or all of the personal data that we hold about you. This is an absolute right when we use your data for direct marketing but may not apply in other circumstances where we have a compelling reason to do so, e.g., a legal obligation.

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6.8 For more information about your privacy rights

The Information Commissioner's Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/forthepublic.

 

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.

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7. How long we keep your information for

 

We retain a record of your personal information in order to provide you with a high quality and consistent service. We will always retain your personal information in accordance with the Data Protection Legislation and never retain your information for longer than is necessary. For more information on how long we retain your data, please contact us.

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8. Giving your reviews and sharing your thoughts

 

When using our website or mobile applications, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts, so you are comfortable with how your information is used and shared on them.

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9. Security

 

Security is of great importance to Oolong Limited and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your collected data.

 

• We take security measures to protect your information including:

• Implementing access controls to our information technology

• We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices and stores.

• Never asking you for your passwords.

• Advising you never to enter your account number or password into an email or after following a link from an email.

 

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10. What happens if our business changes hands?

 

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the purposes for which it was originally collected by us.

 

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11. Changes to our privacy policy

 

We may change this Privacy Policy from time to time (for example, if the law changes). We recommend that you check this policy regularly to keep up to date.

 

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12. How to contact us

 

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us by one of the following means:

 

By email: help@avid.health

 

By post: Profile West, Suite 2 First Floor, 950 Great West Road, Brentford, United Kingdom, TW8 9ES

 

Thank you for taking the time to read our Privacy Policy.

 

Oolong Limited

This Policy was last updated on 08/02/2024

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