KKG Wellbeing Limited T/A Well, Hello Katie!™ (we) operates the website WWW.WELLHELLOKATIE.COM (“Website”) and are committed to protecting your personal data and respecting your privacy.
- Introduction
This policy (together with our end-user licence agreement as set out at (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:
- Our “Website”.
- Any of the services accessible through the “Website” (Services), (this includes its community channels to include all social media, newsletter campaigns, and third party webinar platform). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Website is not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
KKG Wellbeing Limited is the controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this policy). KKG Wellbeing Limited is registered in Ireland under company registration number 735111 and we have our registered office at 2 Station Road, Ballincollig, Cork, Ireland, P31 C799. If you have any questions about this privacy policy, please email us at admin@wellhellokatie.com.
You have the right to make a complaint at any time to the Data Protection Commissioner (DPC), the Irish regulator for data protection issues.
- Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and may amend it.
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 our relationship with you.
- Third party links
Our “Website” may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or Websites.
- Analytics
We may use third-party Website Providers to monitor and analyse the use of our “Website”.
Google Analytics
Google Analytics is a web analytics Website offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our “Website”. This data is shared with other Google Websites. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
You can opt-out of having made your activity on the “Website” available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytis.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes email, shipping, and billing address.
- Financial Data includes payment card details, and payment information. We may use payment information to automatically block certain potentially fraudulent transactions for a short period of time
- Transaction Data includes subscriptions you purchase.
- Device Data includes information about your device which may include hardware and software information such as IP addresses, device ID and type, app settings and characteristics.
- Content Data includes information which you voluntarily disclose on the “Website”.
- Profile Data includes your username and password, preferences, feedback and survey responses.
- Usage Data includes information about how you use our “Website”, products and services.
- Marketing and Communications Data includes your preferences.
- Location Data includes your IP address, which we use to conduct some level of automated decision-making. We may use IP addresses to automatically block certain potentially fraudulent transactions for a short period of time.
- Special Categories of Personal data, this includes information about your health.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you give us about you by filling in forms on the “Website” or by corresponding with us (for example, by email or chat). It includes information you provide when you register to subscribe for membership, make any in-Website purchase, share data via the “Website’s” social media functions, enter a competition, promotion or survey, and when you report a problem with the “Website”. If you contact us, we will keep a record of that correspondence.
- Location Data. We may also use GPS technology to determine your current location. Some of our location-enabled Services may require your personal data for the feature to work. If this is the case, and you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract, we are about to enter or have entered with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
| Purpose/activity | Type of data | Lawful basis for processing |
| To register you as a new “Website” user | Identity Contact Financial | Performance of a contract with you |
| To process “Website” purchases and deliver Services including managing payments and collecting money owed to us | Identity Contact Financial Transaction Marketing and Communications Location | Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) Your consent |
| To manage our relationship with you including notifying you of changes to the “Website” or any Services | Identity Contact Financial Profile Marketing and Communications | Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To enable you to participate in a prize draw, competition or complete a survey | Identity Contact Profile Marketing and Communications | Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) |
| To administer and protect our business and this “Website” including troubleshooting, data analysis and system testing | Identity Contact | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
| To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the “Website” | Identity Contact Content Profile Usage Marketing and Communications Location | Necessary for our legitimate interests (to develop our products/Services and grow our business) Consent |
- to third parties who we engage to provide services to us, such as professional advisers, auditors, insurers and service providers;
- to other members of our organisation or affiliates;
- to third parties, their agents and professional advisors, subject to confidentiality obligations, for the purpose of a due diligence exercise by third parties in connection with any proposed merger, acquisition, re-organisation or transfer of our business and to any person proposing to participate in, promote, underwrite or manage any such arrangement; and
- to competent regulatory or other authorities and bodies as requested or required by law.
- to third party companies and individuals to facilitate our “Website” (“Website Providers”), provide the “Website” on our behalf, perform “Website” related tasks or assist us in analysing how our “Website” is used.
- International transfers
We might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as an area that provides for an equivalent level of protection for personal data as is provided for in the European Union. If, and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission
- Data security
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.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances we will 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.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data as follows:
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 the 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:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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.
If you wish to exercise any of the rights set out above, please contact us at the details set out above.
No fee 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.
- Contact Us
You can exercise any of these rights at any time by contacting us at admin@wellhellokatie.com