Koyo Wellness Limited (“KOYO“, “we“, “our“, or “us“) is committed to protecting and respecting your privacy.
This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) when you use our website (https://www.koyo-wellness.com) or otherwise interact with us, including when contacting us via telephone, WhatsApp, email (together the “Services”).
Koyo Wellness Limited (company no. 14766526) is the data controller of the personal information we hold about you.
Our registered and postal address is 16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH.
Our data protection officer can be contacted at [email protected].
The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
More generally, you may provide us with personal information when you:
Special categories of personal data
Some of the personal information you provide us, including health data, medical history, and certain other sensitive personal information you may choose to provide as part of using the Services will be treated as special category personal data to which additional protections apply under data protection law. You will typically provide this information to us when signing or agreeing our waiver or disclaimer documents.
We process such special category personal data because you have chosen to submit that information to our Services. We will not share this data with anyone other than in accordance with this privacy policy. When completing your account, or providing information to us via the Services, you can provide as much or as little detail as you see fit. For certain procedures, it may be necessary to provide health data and medical history, otherwise we may not be able to provide this procedure.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.
If you have created an account with us, it will be terminated when you decide to terminate your account or after your account has remained paused (“deactivated”) continuously for 1 year. Typically, a user’s account data is deleted 3 months after termination of their account. Please note, however, that we will continue to retain anonymized transactional records and purchase complaint records. We may also retain your personal information for a longer period in certain circumstances, including in the event of an on-going complaint, in the context of a criminal, financial or regulatory investigation (or similar), if we consider on-going retention is needed to protect the health, safety and wellbeing of Koyo staff, other users or other third parties, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We may share your personal information with the following (as required in accordance with the uses set out in Annex 1 or as otherwise described below):
This may also include providers of data hosting, data centre and storage facilities, communications, surveys and chat facilities, user relationship management, social media platforms, marketing communications, advertising, push notifications, technical support, error reporting and fixing, analytics, verification services and/or fraud prevention.
From time to time we may contact you with information about the Services, including sending you marketing messages and asking for your feedback on our Services.
Most marketing messages we send will be by email or Whats App. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you marketing messages if we have your consent or, if consent is not required under applicable law, you have not opted out of receiving messages from us. You can withdraw your consent, or opt out of receiving further communications at a later date, by clicking on the unsubscribe link at the bottom of our marketing emails or, if you are logged in to the Website, toggling your preferences within your account settings or, through Whats App, by responding STOP.
Unsubscribing from marketing emails will not unsubscribe you from system or legal notifications which we may need to send as part of the Services we provide. From time to time we may need to contact you by email or via our support team.
Security. We implement appropriate technical and organisational measures, including encryption, to protect your personal information against accidental or unlawful access, destruction, loss, alteration or damage. All personal information we collect will be stored on our secure servers. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these precautions, however, we cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal information.
International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where our affiliates and our third party service providers have operations. If you are located in the UK, your personal information may be transferred outside of the UK to a country which is not recognised by the UK as ensuring an adequate level of protection for personal data. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard contractual adopted by the UK government. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy policy.
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
Right to object: you also have the right, in certain circumstances, to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive or toggling your preferences in your account settings. See paragraph 6 for further details.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review, remove and edit some of the personal information you have submitted to us by logging into your account on the app.
You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk.
Our website uses cookies and similar technologies to distinguish you from other users of our Services. Please refer to our Cookies Policy at Annex 2 for more information as to the way in which we use cookies on our website and app.
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Services, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Services so that we or our advertising partners may play or display ads on our Services you may use, and on other devices you may use.
Typically, but not always, this information is collected through cookies and similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and to limit some third party advertising cookies, you may wish to visit:
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
Our website(s) may, from time to time, contain links to and from third party websites, including those of our business partners, advertisers, news publications and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
You must not use our Services if you are under the age of 18. No one under age 18 may provide any information through our Services. If you are under 18, you must not use any of our services or features, register an account, make any purchases, or provide any information including but not limited to: your name, address, telephone number, email address, username. We do not knowingly collect personal information relating to anyone under this age. If we learn we have collected or received personal information from an individual under 18, we will promptly delete that information. If you have any information from or about a child under 18, please contact [email protected].
If you have any questions, comments and requests regarding this Privacy Policy, you can contact us:
By post:
FAO Data Protection
16 Great Queen Street
Covent Garden
London
United Kingdom
WC2B 5AH.
By email: [email protected]
This privacy policy was last modified on 8 March 2024.
ANNEX 1 – PERSONAL INFORMATION WE COLLECT
Category of personal information | How we use it | Legal basis for processing
|
Contact details (username, email address, home address and phone number) Profile details (username) | To assist you in creating an account. To register you with the Services. To enable you to use our Services, including: · (where necessary) communicating with us · managing our relationship with you · enforcing our Terms of Service To administer your account (including sending you information regarding changes to our policies, other terms and other administrative information). | Such processing is all necessary to perform our contract with you. (see row below regarding special category data). |
Special category personal data (Health data and medical history and certain other information you may choose to provide as part of using the Services. This would also include information about your race, ethnicity, politics, religion or creed, sexuality, philosophical beliefs, health and sex life) | When you choose certain procedures or services provided by us, we will need to take account this special category data. | Explicit consent (voluntarily submitting such data to us when booking a procedure or informing us in advance) |
Contact details (email address, phone number etc.), payment details (card number, CVC etc.), profile information (username)
| To process your transactions with us. | Performance of a contract. |
Contact details (including name, email address and address) | To communicate with you as regards to billing. | It is in our legitimate interests to communicate with you in respect of billing to ensure we are paid in a timely manner. |
Contact details (including name and post code), bank account details (including account number, sort code etc.) and payment history | To set up your direct debit to pay your initial payment and subsequently take payments from you under this. | Performance of a contract. |
Transaction Data, order history | To obtain an understanding of your preferences. | It is in our legitimate interests to understand our users’ preferences so we can improve the Services and the offers we display on the website. |
To maintain accounts and records. | Compliance with a legal obligation. | |
Contact details
Technical and Usage data
| To verify your identity via SMS or email. | It is in our legitimate interests to verify the email address or phone number you have given during registration is yours to ensure the accuracy of the data and for security purposes. |
Contact details
Marketing details (such as your marketing preferences) Communications data
Technical and Usage data Profile Details | Marketing and advertising (including sending you newsletters and measuring the effectiveness of our marketing). | Consent (if required by law). Where consent is not required by law, it is in our legitimate interests to study how users use our Services and to grow and market our business. |
Contact details
Profile details
Communications data
Marketing details
| To respond to queries and complaints and provide you with information and materials that you request from us. To carry out surveys and/or ask for feedback with a view to improving our Services. | It is in our legitimate interests to respond to your queries and provide any information and materials requested in order for you to have a positive experience with us and to maintain good customer relations. It is in our legitimate interests to understand how our users feel about our Service so we can take steps to improve this. |
Technical information (IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location) Usage data (including clickstream to, through and from the Services, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, interaction information (such as scrolling, clicks, views and mouse-overs), date and time Services are accessed, and Services navigation and search terms used)
| · Analytics (such as analysing usage of the Services) · Improve the Services to ensure that content is presented in the most effective manner for you · Marketing and advertising · To ascertain your preferences | Consent (if required by law). Where consent is not required by law, it is in our legitimate interests to study how users use our Services and to grow and market our business. |
Contact details
Profile details
Communications data
Technical and Usage data | To administer and protect our business and our Services (including troubleshooting, fraud prevention, IT security, data analysis, testing, system maintenance, support, reporting and hosting of data) | It is in our legitimate interests to monitor the Services and resolve errors to ensure that everything functions properly. To comply with our legal and regulatory obligations under applicable law. It is also in our legitimate interests to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us. |
ANNEX 2
KOYO – COOKIE POLICY
We use cookies and similar technologies (“cookies”) on our website.
“Cookies” are small text files, placed on a computer hard drive, that enable websites to remember a particular device. They are widely used to make websites work more efficiently for visitors and to provide web providers with traffic information.
Cookies allow the server to deliver personalized pages for users as cookies remember your preferences and make the interaction between you and the website smoother and more efficient. When users load the website, the browser retrieves their previous activity. This allows the browser to keep the user logged in and many other functions that make the navigation more effective.
Without cookies, we may not be able to provide certain services or features, and our website will not work as efficiently as intended. You can turn cookies off, but if you do this you may not be able to access some of the website.
Cookies may be set either by the website you are visiting (“first party cookies”) or by third parties that run content on the website you are viewing (“third party cookies”). They may be stored either for the duration of your visit or for repeat visits.
There are four main types of cookie:
We also use pixels or web beacons in direct marketing emails that we send to you. These pixels track whether our email was delivered and opened, the links within the email were clicked and which pages of our website you have visited. They also allow us to collect information such as your IP address, browser, email client type, logs of past interactions, and other similar details. We use this information to measure the performance of our email campaigns, and for analytics.
You can always opt-out of our marketing communications by unsubscribing or you can email us (see our privacy policy for further details regarding marketing.
There are various ways in which you can manage and control your cookie settings. Please note that, by deleting or blocking cookies, some or all of the websites you visit (or features of them) may not work properly or as effectively.
To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, you can visit the third party website: www.allaboutcookies.org
Most modern web browsers will provide you with some general information about cookies, enable you to see what cookies you have, allow you to delete them all or on an individual basis, and enable you block or allow cookies for all websites or individually selected websites. You can also normally turn off third-party advertising cookies separately.
Please note that if you adjust your cookie settings via your web browser then, unless you delete or block each cookie individually, the changes will apply to all websites that you visit – not just our website. You will also need to adjust your cookies on a browser-by-browser basis.
We may update this cookie policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons.
The date at the bottom of this cookie policy indicates when it was last updated.
If you have any questions or comments about this cookie policy, or privacy matters generally, please contact us at [email protected].
This cookie policy was last modified on the 8 March 2024.
Last updated: February 04, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Generator.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to KOYO Wellness Ltd, 7 The Quadrant.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: United Kingdom
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to KOYO, accessible from www.koyo-wellness.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies on TermsFeed website article.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, You can contact us:
Redefining Health and Wellness
7 The Quadrant
Richmond, London
TW9 1BP
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