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We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | WeThriveYouThrive Ltd, http://www.elitedealfinder.com |
|---|---|
| Our data protection officer | Kylie Pulling [email protected] |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:
- your name and contact information, including email address and telephone number
- information to check and verify your identity, eg your date of birth
- location data
- your contact history, purchase history and saved items
- information from accounts you link to us, eg Facebook, Meta, Instagram
- Information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
How your personal data is collected
We collect most of this personal data directly from you.
- from a third party with your consent, eg Meta and marketing supplier websites
- text or email
- via our website or apps
- from cookies on our website—for more information on our use of cookies, please see our cookie policy [insert link or directions where to find it, eg which is available on our website]
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given 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 into 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.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Providing products and services to you | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation our financial performance, customer base, product range or other efficiency measures | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations |
| Protecting the security of systems and data used to provide the goods and 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, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating and enhancing customer records | —to comply with our legal and regulatory obligations; —for our legitimate interests, eg making sure that we can keep in touch with our customers about existing deals and new products |
| Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. | For our legitimate interests, ie to promote our business to existing and former customers |
| External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above | Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; —to comply with our legal and regulatory obligations |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR | Relevant categories of personal data |
|---|---|---|---|
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018; | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, and contact information, including email address and telephone number; |
| Direct interactions with users eg sign up to receive newsletters, contact us with a question or issue. | Addressing and sending communications to you, financial administration, invoicing, manage our relationship with customers (eg responding to questions, complaints, asking users to take a survey). To enable users to participate in competitions, prize draws etc. | Processing is carried out as consent has been given Article 4(11) | —your name, and contact information, including email address and telephone number; |
| Analytical Data to improve the customer experience, website functionality and efficiency and to help detect fraudulent activity | In order to improve the website for customers, grow the business, understand what customers prefer and how they utilise the website, improve our marketing efforts and ensure fraudulent activities aren’t being carried out, eg. Bots. | Legitimate interest: Article 6(1)(f) | IP Address, Geographic location, device type, browser, information, screen size, software version preferred language, website activity and browsing information, name, and contact information, including email address and telephone number; |
| Using automated technologies ie cookies or similar technologies when visitors use the website to determine eg geographic location | Financial administration, invoicing and detection of fraud | Legitimate interest: in order to pay third parties and ensure fraudulent activities aren’t being carried out, eg. Bots. Article 6(1)(f) | IP Address, Geographic location, device type, browser, information, screen size, software version and preferred language |
| To find and contact you and display adverts to you on social media platforms or other third party re-marketing tools. | Automatically or manually upload your information into social media platforms, eg. Meta | Processing is carried out as consent has been given Article 4(11) | Email address and telephone number |
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates by email, text message, telephone or post about our products and services, including exclusive offers, promotions or new products and services. You will receive up to 4 emails per week and up to 4 SMS per week.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually 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 do, however, have the right to opt out of receiving marketing communications at any time by:
- contacting us at [email protected];
- using the ‘unsubscribe’ link in emails and ‘Stop’ link in SMS.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations outside the WeThriveYouThrive Ltd group for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help us run our business, eg marketing agencies, suppliers, analytics or website hosts;
- third parties approved by you, eg social media sites you choose to link your account
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—in more detail
More details about who we share your personal data with and why are set out in the table below
| Recipient | Processing operation (use) by recipient | Relevant categories of personal data transferred to recipient |
|---|---|---|
| Commify UK Limited trading as Voodoo | SMS service, ie stores a copy of your personal data so it can be accessed by us in order to send marketing communications that you have consented to receive. | —your name, and contact information, including email address and telephone number; |
| Google Analytics | Analytics processes data, it aggregates and organises the data based on particular criteria like whether a user’s device is mobile or desktop, or which browser they’re using. This is used for example, to improve marketing efficiency and to understand user behaviour on the website to improve the functionality for customers. | —your location, browser and device information and screen resolution; |
| Meta | Uploads a copy of your email address and phone number, this enables us to show you adverts from us on their platforms. It can also be utilised to create audiences that are similar to you. | —your email address, telephone number and how you interacted with our website; |
| Twilio Segment | Analytics processes data, it aggregates and organises the data based on particular criteria like whether a user’s device is mobile or desktop, how they interacted with the website, or which browser they’re using. This is used for example, to improve marketing efficiency and to understand user behaviour on the website to improve the functionality for customers. | —your name, and contact information, including email address, telephone number, your location, IP address, browser and device information; ; |
| Cloudflare | To improve the speed of the website for the customer and reduce fraudulent activity. | —your location, browser and device information and screen resolution; |
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us.
Where your personal data is held
Personal data may be held at our offices and those of our WeThriveYouThrive Ltd, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, if you consent to receiving marketing communications, such as SMS, Email we will not keep it longer than five years past the last time you engage with a correspondence.
If you no longer have an account with us or we are no longer providing services to you, we will usually delete or anonymise your personal data after five years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
- our service providers located outside the UK in USA
We will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK /EEA where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. We rely on adequacy regulations for transfers to the following countries: eg the US
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. We rely on adequacy decisions for transfers to the following countries: USA
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available), eg legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR and/or EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK/EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
International transfers of your personal data outside the UK—in more detail
More details about the countries outside the UK to which your personal data is transferred are set out in the table below.
| Recipient country | Recipient | Processing operation (use) by recipient | Lawful safeguard |
|---|---|---|---|
| USA | Meta | Uploads a copy of your email address and phone number, this enables us to show you adverts from us on their platforms. It can also be utilised to create audiences that are similar to you. | Adequacy decision: 2016/679 of the European Parliament and of the Council on the adequate level of protection of personal data under the EU-US Data Privacy Framework |
| USA | Twilio Segment | Analytics processes data, it aggregates and organises the data based on particular criteria like whether a user’s device is mobile or desktop, how they interacted with the website, or which browser they’re using. This is used for example, to improve marketing efficiency and to understand user behaviour on the website to improve the functionality for customers. | Adequacy decision: 2016/679 of the European Parliament and of the Council on the adequate level of protection of personal data under the EU-US Data Privacy Framework |
| USA | Cloudflare | To improve the speed of the website for the customer and reduce fraudulent activity. | Adequacy decision: 2016/679 of the European Parliament and of the Council on the adequate level of protection of personal data under the EU-US Data Privacy Framework |
Transferring your personal data out of the UK and EEA—further information
If you would like further information about data transferred outside the UK/EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
|---|---|
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consent by [insert details as relevant depending on consents] Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO).
If you would like to exercise any of those rights, please:
- email, or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, email address and phone number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator).
Changes to this privacy policy
This privacy notice was published on 20.11.2024 and last updated on 20.11.2024.
We may change this privacy notice from time to time—when we do we will inform you via our website.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your mobile number or email address—see below ‘How to contact us’.
How to contact us
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email, if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details | Our Data Protection Officer’s contact details |
|---|---|
| WeThriveYouThrive Ltd, Nash Dom, Rhydspence, Whitney On Wye, Wales, HR3 6EY [email protected] | WeThriveYouThrive Ltd, Nash Dom, Rhydspence, Whitney On Wye, Wales, HR3 6EY [email protected] |
Individuals in the EEA
We have appointed Kylie Pulling to be our data protection representative within the EEA. Their contact details are, WeThriveYouThrive Ltd, Nash Dom, Rhydspence, Whitney On Wye, Wales, HR3 6EY, [email protected]
Individuals within the EEA can contact us direct (see above) or contact our European representative.