Effective: May 25, 2018
Wholesum Transformation is committed to ensuring that your privacy is protected. Learn more about the information we collect, how we process the data, and how we respect and secure your privacy.
Wholesum Transformation may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated 25th May 2018.
Purpose and who we are
What You Agree to by Using Our Site
What Information We Collect and How We Collect Them
We collect personal data and/or information from you in various ways:
- When you register on our websites
- When you register on our webinars
- When you book in your calls
- When you book in your coaching sessions
- When you join our social media groups
- When you subscribe to our newsletters
- When you subscribe to notifications from us
- When you affix your signature on our contracts
- When you process payments on any of our services
- When you register for an account, update or change information for your account
- When you purchase products or services
- When you complete a survey or feedback form
- When you log in onto or access third-party sites e.g Facebook, from our site which may include text or images
- When you participate on forums or group discussion e.g Facebook Group or Q&A sessions. Remember that the information you provide in this venue will be publicly available so you should not post information that are too confidential or sensitive.
We may collect the following information:
- name and job title
- contact information including email address and phone number/s
- demographic information such as postcode, preferences and interests
- education and employment history
- other information relevant to customer feedback and/ or promotional materials
- IP address
- URLs which you may have linked to our Site
- operating system
- browsing system used by each user on the site
- log in details to third-party services being used in the program
- bank account details
- credit/ debit card details
You may, however, visit our site anonymously by using the “incognito” or “private” feature of your browser or by disabling cookies.
Other Information We Collect
Social buttons. On many of the pages of Wholesum Transformation sites you will see ‘social buttons’. These enable users to share or bookmark the web pages. There are buttons for: Twitter, Google +1, Facebook ‘Like’, and LinkedIn ‘Share’. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of Wholesum Transformation. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on Wholesum Transformation’s site. So if you click on any of these buttons, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that you are visiting Wholesum Transformation, and the specific pages you are on, even if you don’t click on the button if you are logged into their services, like Google and Facebook.
You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
External web services. We use a number of external web services on Wholesum Transformation sites mostly to display content within our web pages. For example,to display slideshows we sometimes use SlideShare; to show videos we use YouTube and Vimeo. This is not an exhaustive or complete list of the services we use, or might use in the future, when embedding content, but these are the most common. As with the social buttons we cannot prevent these sites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads etc.
Email tracking. Some emails that we send you have no tracking in at all, for example personal correspondence or emails with invoices attached. Other emails we send we put in tracking so that we can tell how much traffic those emails send to our site and we can track, at an individual level, whether the user has opened and clicked on the email. We rarely use the latter information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. Sometimes we do use the personal information e.g. to re-email people who didn’t click the first time. If you want to be sure that none of your email activity is tracked then you should unsubscribe from the our newsletter.
What We Do With The Information We Gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- We may send you information of offers outside of Wholesum Transformation that will be of your interest.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
Providing the Site and our services. We may use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products or services that you request from us.
Updates. We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an Online Course. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
Identity Verification. For services that require identity verification, we use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor.
Disclosure to Wholesum Transformation Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Online Course. Access to your Personal Data by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.
Third Party Credit Card Processing. Wholesum Transformation provides you with the ability to pay for Online Courses and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not Wholesum Transformation – collects and processes your credit card information.
Retention of Personal Data
If you reside or are located in the EEA, we keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. Unless mentioned otherwise we keep personal data indefinitely unless explicitly instructed to delete it.
Confidentiality & Security of Personal Data
Wholesum Transformation implements a variety of security measures to maintain the safety of your personal data when you enter, submit, or access your personal data.
We care about the security of our users. While we work to protect the security of your account and related information, we cannot guarantee that unauthorized third parties will not be able to defeat our security measures. Please notify us immediately of any compromise or unauthorized use of your account by emailing [email protected].
Controlling, Updating or Deleting Your Personal Data
You may choose to restrict the collection or use of your personal data in the following ways:
• Whenever you are asked to fill in a form on the website, look for the box that you can uncheck to indicate that you do not want the information to be used by anybody for direct marketing purposes
• If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email protected].
• We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via [email protected]. If you reside or are located in the EEA, you have the right to request that we:
- provide access to any Personal Data we hold about you;
- prevent the processing of your Personal Data for direct-marketing purposes;
- update any Personal Data which is out of date or incorrect;
- delete any Personal Data which we are holding about you;
- restrict the way that we process your Personal Data;
- provide your Personal Data to a third party provider of services; or
- provide you with a copy of any Personal Data which we hold about you.
We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personal Data to comply with a legal obligation.
When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
International Privacy Practices
Wholesum Transformation’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personal Data may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Data. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.
No Information from Children Under 13
Wholesum Transformation strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personal Data on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personal Data.
The material on our site is given for general information only, and does not constitute professional advice. You should take specific advice before taking a course of action as we do not accept directly or indirectly any responsibility for loss arising directly or indirectly from reliance on information on this site.
Given that the Internet uses an open system we cannot warrant that the site and downloads reach you virus-free. You must, therefore, take all appropriate precautions for your own safety.