Privacy & Policy

Hey mama. We’re so excited you’ve found your way to wellmama. Welcome to our Privacy Policy. This is the low-down on all things Privacy related, and we’re sharing it to protect you and us. So take a moment to read it (maybe with a nice cup of tea) before enjoying our site. That way you can know and feel secure about how we process your data.

This Privacy Policy explains how and why we collect and process your personal data when you visit our website (www.wellmama.life) and use our services. This includes the way we use any personal data you provide through this website, such as if you leave User reviews, opt-in to marketing or sign up as an Expert. It also tells you about your privacy rights and how to get in touch with us about privacy.

You should read this Privacy Policy together with any other notices we provide to you, so that you are fully aware of how and why we are using your data.

wellmama is committed to protecting your personal data in accordance with applicable data protection laws, including the UK’s Data Protection Act 2018 and the General Data Protection Regulation (“Applicable Data Protection Laws”).

This Privacy Policy covers the following information, provided in a layered format so you can click through to the areas set out below.

• Introduction
• Who our Privacy Policy applies to
• Who we are and contact details
• The data we collect about you
• How is your personal data collected?
• How we use your personal data
• Disclosures of your personal data
• International transfers
• Data security
• Data retention
• Your legal rights
• Changes
• Third party websites

In this Privacy Policy, “you” means any user of our website and/or services, and includes both our Users” (new, expectant and future parents seeking advice) and “Experts” (service providers whose services are listed on our website and experienced parents or caregivers who contribute to our content). Our Experts may be corporations, however we recognise that they can also be individuals and to that extent we have included details in this Privacy Policy about how we process the personal data of our Experts. Parts applicable to only Users or Experts are indicated accordingly.

Whilst wellmama is primarily aimed at adult Users, we also want to provide support for older teens who may highly value our service. Therefore we have an age policy which allows Users between the ages of 15 and 18 to use our website when accompanied by a caring adult, and we provide specific guidance to that age group in our Village Rules on how to safely use our website, as well as ensuring all information about our use of their personal data is clear in this Privacy Policy and their rights easily exercisable. Where possible we collect the date of birth of Users to monitor adherence to our age policy.

We do not knowingly work with any Experts under the age of 18.

Wellmama & Partners Limited is the data controller and responsible for your personal data processed under this Privacy Policy (collectively referred to as "wellmama", "we", "us" or "our" in this Privacy Policy).

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights or questions about our privacy practices, please contact us in the following ways:

• Full name of legal entity: Wellmama & Partners Limited
• Email address: info@wellmama.life

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity and Contact Data: This includes data such as first name, last name, email address, telephone number.
• Expert Public Profile Data: This is Expert personal data which appears on their profile on our website, which includes (to the extent provided) Expert Identity and Contact Data, profile photo, postcode of the Expert’s operational base, city and country of residence, languages spoken, gender, self description, education and qualifications, work history, links to further information on other sites, whether the Expert will provide qualifications/references, whether they’ve had a DBS check and have insurance and details of the services offered by the Expert.
• Expert Account Data: This includes Expert username and password or personal data required for social login, and any information required to manage the Expert account with us. This includes Experts’ payment method information, to the extent Experts provide it for subscription purposes, and details of any transactions.
• Expert Contributions: This includes the personal data in any content provided by Experts for use on wellmama’s content pages or social media, such as blogs and mama story instagram posts (including lives, videos, written content and photos).
• Feedback Data: Your feedback and survey responses.
• Marketing and Communications Data: This includes your preferences in receiving marketing from us and any third party partners, and any direct communications between us.
• User Review Data: This includes any personal data provided in, or in association with, reviews on our website, including information used to authenticate you.
• Usage Data: This includes information about how you use our website and services.
• Technical Data: This includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

We also collect, use and share Aggregated Data such as web analytics data. Aggregated Data is data that is sometimes derived from your personal data but is not considered “personal data” in law as it will not directly or indirectly reveal your identity. For example:

• we aggregate your Usage Data and provide it to Google Analytics in order to analyse the general usage and success of our website, including the click rate on certain pages or features. Your Usage Data is made into Aggregated Data before it is shared with Google Analytics for this purpose; and
• we may also share Aggregated Data in the form of website statistics with Experts for visibility over the popularity of their profile.

Except for any Sensitive Personal Data (such as about mental health or physical experiences) which Experts may voluntarily provide to us in their Expert Contributions, we do not collect any Sensitive Personal Data about our Users or Experts. Sensitive Personal Data would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Whilst we store whether an Expert has a DBS check certificate, we do not store information about where a DBS check has been failed, so we don’t collect any information about criminal convictions and offences.

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 Experts with a profile page on our website). 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.

We use different methods to collect data from and about you including through:

• Direct interactions. Most of the personal data we process about you is provided by you directly via our website or direct communications. This includes the following:
  • We collect Expert Public Profile Data (including Identity and Contact Data), Expert Account Data and Expert Contributions directly from Experts.
  • Certain User Review Data is provided directly by Users when leaving a User review.
  • Your Identity and Contact Data, Feedback Data and Marketing and Communications Data is provided by you when requesting to receive marketing, providing feedback or surveys or when communicating with us directly.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.
• Third parties and publicly available sources. We receive personal data from the following third parties and public sources:
  • social media platforms which Experts may use to sign up to to our website, who will provide us with certain Expert Public Profile Data such as profile photo, email address and first/last name;
  • social media platforms which share User personal data with us if you elect to use them to authenticate your User reviews (including your first and last name, email, profile photo and where possible your date of birth to verify that you meet our age policy);
  • in certain cases the employers of Experts, where the employer is legally able to provide it; and
  • from publicly available sources, such as LinkedIn.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances (these are “Legal Grounds”):

• Where we need to perform the contract we are about to enter into or have entered into with you. Our contract with Users is the Site Terms, and our contract with Experts is the Expert Terms.
• 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.
• We rely on consent as a Legal Ground direct marketing communications and for Expert Contributions which contain Sensitive Personal Data. We explain how to opt out of marketing in the Marketing section below, and you can withdraw your consent to our use of your Sensitive Personal Data in Expert Contributions by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the Legal Grounds we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one Legal Ground depending on the specific purpose for which we are using your data. Please contact us if you need a more detailed explanation.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

• Your choice

You will receive marketing communications from wellmama about the wellmama platform if you have given your consent to receive them.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

• Opting out

You can ask us or third parties to stop sending you marketing messages at any time 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 operational or legal messaging.

• Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

We will only use your personal data for the purposes for which we collected it as set out in this Privacy Policy or for a compatible purpose. If we need to use your personal data for an unrelated purpose, we will update this policy or notify you.

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.

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Expert Public Profile Data is shared with Users on our website.
• A User’s name, photo and review are only shared publicly if the User gives permission for them to be shared when leaving a review. If a User elects to withhold their personal details from the review, their details are not shared on our website but may be shared with our Experts if necessary to resolve a dispute.
• Third Parties:
  • Collaboration partners when you agree to receive marketing from our partners.
  • Service providers acting as data processors based in the UK, EU and US who provide IT, hosting, communications management and system administration services.
  • Professional advisers acting as data processors and independent data controllers, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as data processors or independent data controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Some of our third parties are based outside the EEA, including the US, so their processing of your personal data will involve a transfer of data outside the EEA. Whenever a transfer of personal data occurs to a country outside the EEA there is a risk that it may not be protected to the same extent as under EU data protection law.

In order to combat this risk, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring a legally compliant safeguard is implemented, which currently include:

• The transfer of your personal data is limited to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (listed here); or
• The use specific contracts approved by the European Commission (Standard Contractual Clauses) with service providers which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data 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.

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 Experts (including Identity and Contact Data and Expert Account Data relating to payment methods and transactions) for six years after they cease being customers for tax purposes.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the following rights:

• The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
• The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law.
• The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold.
• The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you.
• The right to restrict processing. You have rights to 'block' or 'suppress' further use of your information. When processing is restricted, we can still store your information, but will not use it further.
• The right to data portability. You have the right to obtain your personal information in an accessible and transferable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions.
• The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.
• The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us. Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
• The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by getting in touch.

If you wish to exercise any of the rights set out above, please contact us using the details in this Privacy Policy. 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.

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 your 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.

This Privacy Policy was last updated on [26 October 2020].

This Privacy Policy may be updated from time to time so you may wish to check it each time you provide personal data to us. We won’t alert you to minor changes, but if there are any major changes we will let you know.

It is also 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.

Our website contains hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.