Privacy and Cookies Policy

We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information.

This policy is divided into three parts:

• Part A provides information about our collection and use of personal information;
• Part B provides information about the cookies used on this website; and
• Part C contains information about us (including contact details).

We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

PART A: YOUR PERSONAL INFORMATION

• What information do we collect?

• We may collect, store and use the following kinds of personal information:

• • information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation
  • information relating to any transactions carried out between you and us on or in relation to this website
  • information that you provide to us for the purpose of registering with us (including data entered into your personal profile)
  • information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters
  • any other information that you choose to send to us; and
  • demographic data

• Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with the terms of this policy.

• Using your personal information

• This is your space to track your progress and set goals. It’s your supportive community designed to encourage, motivate and most importantly support your journey.

• To help you on your Best-You journey we will support you with a weekly round-up of Best-You activity and a health and happiness Sunday message. If you would prefer not to receive support emails you can opt out by selecting the appropriate settings during your account setup. You can also alter these at any time by visiting your settings page within Best You.

• Personal information submitted to us via this website will be used for the purposes specified in this policy or in relevant parts of the website.

• We may use your personal information to:

• • administer the website;
  • improve your browsing experience by personalising the website;
  • enable your use of the services available on the website;
  • send you general (non-marketing) commercial communications;
  • send you email notifications which you have specifically requested;
  • provide third parties with statistical information about our users - but this information will not be used to identify any individual user;
  • deal with enquiries and complaints made by or about you relating to the website;
  • keep the website secure and prevent fraud;
  • verify compliance with the terms and conditions governing the use of the website (including monitoring private messages sent through our website private messaging service); and
  • when required to by law or when disclosure is reasonably necessary to protect the rights of us as the owners of BestYou, third parties or the public at large.

• Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

• Your privacy settings can be used to limit the publication of your information on the website. You can adjust your privacy settings in the profile section of the website.

• We will not, without your express consent, provide your personal information to any third parties for the purpose of direct marketing.

• Best-You reserves the right to transfer all personal information in its possession to a successor organisation in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of BestYou assets. The use and disclosure of all transferred personal information will be subject to this privacy policy or a new privacy policy. You will be given notice of the new privacy policy and an opportunity to opt out of it.

• Disclosures

• We may disclose your personal information to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

• We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

• In addition, we may disclose your personal information:

• • to the extent that we are required to do so by law;
  • in connection with any ongoing or prospective legal proceedings;
  • in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  • to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
  • to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

• Except as provided in this policy, we will not provide your information to third parties.

• Security of your personal information

• We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

• We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

• All electronic transactions entered into via the website will be protected by encryption technology.

• You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

• You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to the website).

• Policy amendments

• We may update this policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

• We may also notify you of changes to our privacy policy by email.

• Managing your Data

• We record and process your data in line with current Data Protection Act legislation which from 25^th May 2018 will include the content of the General Data Protection Regulations as amended by UK Law

• We will not share your data with other organisations without your agreement and your data will not be transferred outside of UK.

• We will either obtain consent from you to process your data or rely on an existing legal basis for the processing of data.

• We will regularly review consent to check that the relationship, the processing and the purposes have not changed.

• We have processes in place to refresh consent at appropriate intervals, including any parental consents. It is an easy process for individuals to withdraw consent at any time, and we act on withdrawals of consent as soon as we can. Additionally, we don't penalise individuals who wish to withdraw consent, however, it should be noted that we may not be able to provide our services to you without your agreement to process your data - this is for clinical and safety reasons.

• How long we keep your personal information

• We will keep your personal information for as long as your account remains active

• When your account has been inactive for a period of 5 years, we may retain your data for up to 5 years following the end of your involvement with us to comply with one or more of the reasons listed below:

• • To respond in a timely and accurate way to your questions or complaints.

  • To demonstrate that we have treated you in line with our clinical and administrative processes.

• We may keep your data for longer than 5 years if there are reasons why we can't remove it for lawful, supervisory or practical reasons. We may also keep your data in an anonymised format for research or statistical purposes. Will ensure that your private and personal data is protected at all times and that it is only used for legitimate purposes.

• Consent

• Consent is one of the appropriate lawful basis for processing and have made the request for consent prominent and separate from our terms and conditions when we ask people to positively opt in.

• We don't use pre-ticked boxes, or any other type of consent by default in fact we use clear, plain language that is easy to understand and inform you specifically why we want the data and what we're going to do with it.

• You have the right to withdraw your consent without detriment to you and you have the right to refuse to consent without detriment. You also have the right to request a copy of the information we hold about you in an easy to read and transferable format

• Managing Consent

• We record consent by storing when and how we were provided with your consent and exactly what you were told at the time.

• We will not share your data with other service providers without your agreement and your data will not be transferred outside of the UK.

• We regularly review consent to check that the relationship, the processing and the purposes have not changed.

• We have processes in place to refresh consent at appropriate intervals. It is an easy process for individuals to withdraw their consent at any time, and we act on withdrawals of consent as soon as we can. Additionally, we don't penalise individuals who wish to withdraw consent.

• Your rights

• From 25^th May 2018 as a result to the new data Protection Act and GDPR you will have additional rights to: -

• Be informed of what data we keep about you

• Be able to have access to your data

• Request rectification of errors in your data as you may question any data we hold about you if you consider it is incorrect, incomplete or wrong.

• Request erasure of your data, sometimes known as the 'right to be forgotten'. You have the right to request that we stop using your data if there is no requirement for us to keep it, however, on some occasions there may be legal or other reasons why we will keep or use your data.

• Request that we restrict processing of your data and only use part of your data

• Apply for us to provide you with data portability or the request for us to provide your data in an easily transferable format

• The right to object to the way we treat your data if you think it is unfair

• Request that we do not use automated decision making and profiling when dealing with your data

• • How to withdraw your consent

  • You can withdraw your consent at any time. Please contact us at best-youdataprotection@best-you.org if you want to do so.

  • If you withdraw your consent, we may not be able to provide certain services and information to you.

  • How to complain

  • Please let us know if you are unhappy with how we have used your personal information.

  • You also have the right to complain to the Information Commissioner's Office. Find out on their website how to report a concern. The ICO address is: -

  • Information Commissioner's Office

  • Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF

• Third party websites

• The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.

• Updating information

• Please let us know if the personal information which we hold about you needs to be corrected or updated.

PART B: COOKIES

• About cookies

• A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

• Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.

• Cookies may be either "persistent" cookies or "session" cookies.

• A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date).

• A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

• Our cookies

• We use both session cookies and persistent cookies on this website.

• Session cookies are essential for this website to function, for example to mark someone as being logged in.

• The persistent cookies we use are non-essential but harmless, for example we may use them in order to:

• • provide extra security features such as preventing cross-site request forgery (CSRF) attacks;
  • remember when you've already completed (or decided not to) one of our survey.
• Third party and analytics cookies

• When you use our website, you may also be sent third party cookies.

• These are including but not limited to You Tube, Facebook, Twitter, Google+, Linkedin, Pinterest etc.

• Our advertisers / service providers may send you cookies. They may use the information they obtain from your use of their cookies:

• • to track your browser across multiple websites;
  • to build a profile of your web surfing; and
  • to target advertisements which may be of particular interest to you.

• In addition, we use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: https://policies.google.com/privacy

• Cookies and personal information

• Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

• Blocking cookies

• Most browsers allow you to refuse to accept cookies. For example:

• • in Internet Explorer (version 9) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
  •  
  • in Firefox (version 16) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
  •  
  • in Chrome (version 23), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

• Blocking all cookies will, however, have a negative impact upon the usability of many websites.

• If you block cookies, you will not be able to use all the features on this website.

• Deleting cookies

• You can also delete cookies already stored on your computer. For example:

• • in Internet Explorer (version 9), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
  •  
  • in Firefox (version 16), you can delete cookies by clicking "Tools", "Options", "Privacy" and then "Show Cookies", and then clicking "Remove All Cookies"; and
  •  
  • in Chrome (version 23), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data".

• Again, doing this may have a negative impact on the usability of many websites.

• Cookie preferences

• You can manage your preferences relating to the use of cookies on our website by visiting: best-you.org

PART C: OUR DETAILS

• Contact us

• This website is owned and operated by ICE Creates Limited.

• If you have any questions about our cookies or this policy, please contact us:

• • by email (to admin@best-you.org);
  • by telephone (to 0845 5193 423);
  • by post (to ICE Creates Limited, Unit 2-3 Abbots Quay, Monks Ferry, Wirral CH41 5LH).

• How to request a copy of your personal data

• You can request access to your personal information we hold by emailing admin@best-you.org and requesting a 'Subject Access Request form' or by writing to us at this address:
  

• Ice Creates Ltd
  Unit 2-3 Abbots Quay
  Monks Ferry
  Birkenhead
  CH41 5LH

• Data controller

• The data controller responsible in respect of the information collected on this website is ICE Creates Limited.

• Our data protection registration number is Z752432X