Walking on Earth’s Privacy Policy
Last Updated: April 20th, 2023
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 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 Wellbeing Service bookings are made who we refer to as "Users" and users of the Services on whose behalf we offer the Wellbeing Services who we refer to as “Practitioners”.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Walking on Earth Limited
Email address: support@walkingonearth.com marked ‘For the attention of the Data Protection Officer
Postal address: Walking on Earth Limited, International House, 24 Holborn Viaduct, London, United Kingdom, EC1A 2BN
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review.
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 your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
- 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. It does not include data where the identity has been removed (anonymous data). 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 (optional), date of birth (optional), email 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.
- Transaction data includes details about payments to and from Users.
- Wellness Data such as resting heart rate, heart rate variability, sleep, and step count. We may use certain parts of this information to customise your experience with us as part of our Services.
- 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.
- Online activity data such as the pages or screen you view, and how long you spent on a screen or session.
- Profile data includes your browsing history, demographic information, feedback and survey responses, preferences, interests and any data you have made available 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.
- Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
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.
- How we collect your data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- connect your social media or other accounts with our platform, or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Technical Data from the following parties:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Payments UK Limited based inside the UK.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources.
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
- 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;
- Provide, improve, develop, and personalise the Services, including testing, research, analysis and product development;
- 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 on 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, with the option to unsubscribe;
- send you promotional messages, marketing, advertising and other information based on your preferences through our social media platforms with the option to unsubscribe;
- detect and prevent fraud, spam, abuse, security and safety incidents, regulatory compliance, risk assessment and other harmful activity.
- where we need to perform the contract we are about to enter into or have entered into 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages or notifications at any time by logging into the site and checking or unchecking relevant boxes to adjust your preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- 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.
- Data retention
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see your rights below for further information.
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,
- 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.
- 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;
- Push notifications and device permissions to request full deletion of your account and corresponding data.
- You can disable collection of Wellness Data by unpairing your device connection in the settings section of the app.
- 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.
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. 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 the 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.
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.
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.
- 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.
- 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.
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.
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.
- 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.
- 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.
- 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.