Walking on Earth’s Privacy Policy

Last Updated: November 3, 2020

Welcome to Walking on Earth Ltd’s (“Walking on Earth”, "us", "we" or "our") Privacy Policy. Walking on Earth Ltd is a company incorporated in England under the company number 12433843 and the registered address at 24 Holborn Viaduct, London, EC1A 2BN, United Kingdom.

When you use Walking on Earth, you trust us with your personal data. We are committed to keeping this trust. This Privacy Policy describes the data we collect, how it’s used and shared and the rights you as a user have to control the use of your information. This policy explains how we, as data controller, collect, use and share the information that we receive or collect about you (that may include personal information) through our website and our App “Walking on Earth” (collectively referred to as "the Site") which you can use to book holistic wellbeing services (referred to as "the Services"), and through other interactions you may have with us. In this Policy we distinguish between users of the Services on whose behalf Holistic Wellbeing Service bookings are made who we refer to as "Users" and users of the Services on whose behalf we offer the Holistic Wellbeing Services who we refer to as “Practitioners”.

Please read this carefully before you start using the Site.

  1. Personal information we collect

    Personal data, or personal information means any information about an individual that allows that person to be identified either directly or indirectly. We may collect, user, store and transfer different personal data relating to both Users and Practitioners which we have grouped together as follows:

    • Identity data includes first name, last name, gender, date of birth, username and User and Practitioner password details.
    • Contact data includes billing address, delivery address, email address and telephone numbers.
    • Financial data includes bank accounts of Practitioners in order to pay them for the Services and payment card details of Users to manage payment for Services on behalf of the Practitioners.
    • Technical data includes internet protocol (IP) address, your login data (password), browser type and version, time zone setting and location, browser plug-in types and versions, cookie data, operating system and platform and other technology on the devices you use to access the Site.
    • Operational data including interaction with the Services and transcripts from calls, messages from both Users and Practitioners.
    • Location data including data that is used to enable the Practitioner to find the User in order to perform the Services and the User to check the arrival of the Practitioner.
    • Marketing and communications data including preferences in receiving marketing from Walking on Earth and our third parties.
    • Usage data including information on how Users use our Site, Services, and features.
    • Profile data includes your browsing history, demographic information, feedback and survey responses, preferences, interests and any data your have made availabile on our social media networks.
    • Aggregated data including data that is collected, used and shared such as statistical or demographic data for any purpose, such as to analyse trends. Aggregated Data is not considered by the law as personal data because it does not reveal your identity.

    Relating to Users only:

    • Work related data - We work with businesses to deliver our Services to their employees. If you are employed by one of those businesses, to use the Services you will need to sign up with us. We will collect information from you directly when you do this and we will also be able to associate this with information provided by your employer, such as your job title.
    • If you choose to, you can turn on Feedback Reports. This feature is only turned on with your consent. The Feedback Reports allow Practitioners to record progress and suggestions to get you to meet your wellbeing goals. Only if you turn this feature on will Practitioners that you book a Service with be able to see this information.

    Relating to Practitioners only:

    • Certification data including information on accreditations and qualifications, contact logs, performance and ratings.
    • Profile data including photographs, videos, biography, services offered and schedule information.

    How we use the information

    We will use this information to administer the Services and for internal operations, including troubleshooting, data analysis, testing research and statistical survey purposes. We will also use this information to measure the effectiveness of how we present content and deliver our Services and how we market and advertise. This information will also be used to allow you to participate in the interactive features of our Services, when you choose to do so. It is always your choice whether or not to provide information. If you do not provide certain information however, you may not be able to use certain features of the website or app or be provided with certain Services.

    Information we may collect from other sources

    Information may be gathered from our affiliates and third-party sources, including without limitation:

    • Third-Party Service providers including if you link, connect, or login to the Site with a third party service you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
    • Background Information including police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
    • Referrals including if you are invited to the Site on a referral, the person who invited you can submit personal information about you such as your email address or other contact information.
    • Other Sources such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address, and your operating system. We may collect personal details from available sources to which you give your details or from your company's website to contact you in our legitimate business interests with business opportunities which we think might be required from you.
  2. How we use your personal data

    We use personal information to:

    • identify Users and Practitioners when they sign in to their account;
    • to process bookings of Services on behalf of Practitioners, send confirmation of bookings, reschedules or cancellations;
    • provide customer service;
    • perform analytics, debug and conduct research to improve and expand our offerings;
    • send messages, updates, security alerts, notifications and reminders;
    • administer User and Practitioner accounts;
    • assess and verify qualifications and credentials of Practitioners and to create and maintain profiles of Practitioners;
    • manage and process the collection of payment of behalf of Practitioners;
    • personalise the experiences based on the Users and Practitioners interactions with the Site, search and booking history, profile information, preferences and any other content submitted;
    • where you have not objected, send you information which we think you may find useful or which you have requested from us, including marketing communications such as emails about any improvements to the Services, special offers or promotions, events, competitions, new Services;
    • send you promotional messages, marketing, advertising and other information based on your preferences through our social media platforms;
    • detect and prevent fraud, spam, abuse, security and safety incidents, regulatory compliance, risk assessment and other harmful activity.
  3. Purposes for which we will use your personal data

    We have set out below a description of the ways we plan to use your personal information and the legal basis or bases which we rely on to do so.

    Purpose Type of data Lawful basis for processing
    To register a new User or Practitioners when you sign up and identify you as a User or Practitioner when you sign in Identity, contact, technical Performance of a contract with you
    To maintain profiles on Practitioners including photograph(s), videos, biography, services offered. Identity, contact, assessment, profile Performance of a contract with the Practitioner and User, in our legitimate interests in maintaining and improving the running of the Services
    To process and transmit a booking from the User to the appropriate Practitioner including managing payments and location Identity, contact, profile, assessment, location, technical, transaction, operational Performance of a contract with you; in our legitimate interests
    To assist Users and Practitioners with queries via email and messages on our site Technical, operational, identity, contact Performance of our contract with you; in our legitimate interests to resolve problems to ensure our Services run as smoothly as possible
    To administer and protect our Site (including troubleshooting, data analysis, testing, system maintenance, support, and system review) Identity, contact, technical In our legitimate interests to run our Site, manage administration and IT services and safeguard network security
    To manage our relationship with Users and Practitioners by sending emails to confirm, cancel or change bookings Identity, contact, technical, transaction Performance of our contract with you; in our legitimate interests to maintain and improve our Services
    To ask Users to complete reviews or feedback Identity, contact, usage, profile In our legitimate interests to understand how Users use, enjoy and rate the Services to ensure practitioner standards are maintained
    To allow Users and Practitioners to take part in promotions, events or competitions Identity, contact, usage, marketing and communications With consent where required by law in or where Users have not objected; in the legitimate interests of the business
    To make recommendations to Users Identity, contact, usage, profile, marketing and communications, aggregated data In the legitimate interests of the business to develop and grow
    To advertise our Site and Services Usage, marketing and communications, aggregated data With consent as required by law, in the legitimate interests of the business to develop and grow
    To notify Users and Practitioners about any changes to our Site, Privacy Policy or Terms and Conditions Identity, contact Performance of a contract and in the legitimate interests of the business in the smooth running of the Services
    To maintain a blacklist/fraud identity system Identity, contact, financial In the legitimate interests of the business to protect the business from fraud
    To record Feedback Reports by Practitioners Feedback report Consent is required from Users to share Feedback Reports with other Practitioners
    To gather location data on Users and Practitioners in order to inform of the location in which the session takes place Identity, contact, location Necessary to fulfil the contract for services, in our legitimate interests to provide Services that are as efficient and smooth running as possible
    To provide mediation between User and Practitioner in the event of a complaint Identity, contact, assessment, financial data Necessary to fulfil the contract for services for the User, in our legitimate interests to provide Services

    We may from time to time collect other types of personal information including information you voluntarily give us.

    If you are a practitioner, you are responsible for ensuring that you comply with applicable data protection law in respect of any personal information that you collect about Users in the provision of the Services. If you are a User, you are responsible for any misuse of personal information that you may collect in the course of your receipt of the Services. Walking on Earth does not accept any responsibility for this processing of personal data.

  4. Disclosing your information

    We may need to share the following personal data with the following parties:

    • User data with Practitioners to assist them in the providing the services booked by Users;
    • Practitioner data to Users to assist them in selecting a Practitioner to book a Service with;
    • affiliates, consultants and contractors who support our business and operations including, inter alia, processing transactions, fulfilling requests for information or assistance, receiving and sending communications, analysing data, providing other support services such as advertising, PR, events related services and other web related services such as web hosting and web-monitoring services including analytics providers and search information providers;
    • prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes;
    • third parties to whom we may sell, transfer, or merge our business or assets;
    • courts, regulators or authorities if legally entitled or required to do so.
  5. Payment Processing

    All payments transactions made through the Services are conducted through our payment provider Stripe. You will be providing credit or debit card information directly to these providers who process payment details, encrypting your credit/debit card information and authorising payment. When you use Stripe to process your payment, you will stay on our Site but will provide your information directly to the payment providers. The processing of your payment information is done so in accordance with these third parties' own privacy policies and terms.

  6. Your Rights

    You can exercise any of the following rights consistent within applicable law:

    • To access and update your personal information through your profile settings;
    • To request certain copies of your personal information or information about how we handle your personal information;
    • To request the erasure of your personal information;
    • To request that we stop processing your personal data in certain circumstances;
    • To object to our processing of personal data for the purposes of sending you direct marketing emails;
    • To request that we restrict the processing of your personal information while we verify or investigate your concerns;
    • To request that your information be transferred to a third party.

    We may need to retain certain personal information even once an account has been closed for legitimate business interests, such as prevention of money laundering, fraud prevention, to identify, issue or resolve any legal claims, or for proper record-keeping purposes. We may retain certain information following any objection indicated by you to receiving marketing communications for the purpose of ensuring that your wishes continue to be respected and we do not contact you further.

  7. External Links

    The Site may contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We have no control over these third parties and we are not responsible for the content of such websites or for the privacy policies or practices of such third parties.

  8. Security

    We place great importance on the security of all personal information associated with both Users and Practitioners. We have implemented appropriate technical and administrative measures to help protect your information against unauthorised access, destruction, loss, or alteration. In addition, we limit access to this information to only those who have a business need to know. They will only process it on our instructions and they are subject to a duty of confidentiality.

    No electronic data transmission over the internet or storage of information can be guaranteed to be completely secure or error free and we therefore cannot warrant or guarantee the security of information you submit via the Site or Service transmitted to our Site or Service and any such submission is at your own risk.

  9. Data Storage And International Transfers

    Information that you submit via the Services is sent to and stored on secure servers located inside and outside the European Economic Area (“EEA”), for example in the United States. Where we transfer your information outside the EEA in this way, we will take steps to require that your privacy rights continue to be protected. By way of example, and as mentioned above, we work with key service providers such as Google, Facebook, Amazon Web Services and we have signed data processing addendums which reflect data transfer mechanisms to provide adequate protection to the personal data transferred outside the EEA.If you would like further information on this, please do contact us.

  10. Changes To This Privacy Policy

    We reserve the right to modify this Privacy Policy at any time in accordance with the applicable law. If we do so, we will notify you before they take effect either through the Site or by sending you a notification. Any material changes will only apply to personal information collected after the revised Privacy Policy takes effect.

  11. Contact Us

    If you have any questions about our Privacy Policy or any questions about the security of our Site, please contact us at support@walkingonearth.com

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