BeSophro Website Privacy Policy

What does this policy cover?

This policy describes how BeSophro (“BeSophro”, “we”, “us” and “our”) will make use of your data when you use our services or visit our website or other online services or applications (“Services”).

It also describes your data protection rights, including a right to object to some of the processing which BeSophro carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?

The following categories of personal data will be collected about you in connection with your use of the website and your interaction with us, including, but not limited to, when you fill in forms on the website, and submit user-generated reviews or ratings, engage in any social media functions on the website:

  • Personal identification information: such as your name, date of birth and gender;
  • Contact information: such as your email address and telephone number;
  • Demographic information: such as your address;
  • Lifestyle information: such as sleeping habits, emotional condition and social circumstances.
  • Health data relevant to your session, such as details of any medication you are taking;
  • Your marketing preferences, including any consents you have given us; and
  • Information related to the browser or device you use to access our website.

In addition, if you contact us by phone, email or otherwise, we may keep a record of that correspondence.

What information do we receive from third parties?

Sometimes we receive personal data about you from third parties. When you engage with our content through social media, or other non-BeSophro, sites or applications, those sites will share personal data with us about the content you have viewed or interacted with and about adverts within the content which you have been shown or clicked on.

The privacy policies for these sites and applications will contain more detail about this and how to change your privacy settings on those sites and applications.

How do we use this information, and what is the legal basis for this use?

We rely on the following lawful basis for processing your data:

  • Where necessary to fulfil our contract with you, or to take steps in order to enter into a contract with you. This includes, for example:
    • using your information to provide products and services you have requested, such as support during the 1to1 sessions and access to your Sophrology Recording;
    • taking payments;
    • communicating with you and providing customer services;
    • processing your registration details for entry to a prize competition, or giveaway; and
    • sending you information about changes to our terms or policies.
  • our legitimate interests in conducting our business and carrying out the administrative processes required to carry out our business, in particular:
    • we use your data to administer our business, manage appointments, coordinate with subcontractors, service providers and business partners that assist us in providing our services, for billing purposes, to manage client communications including marketing, to maintain a record of our business and to maintain our accounts;
    • we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
    • we use information you provide to personalise our website, products or services for you;
    • to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law;
    • we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
    • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
    • we use data of some individuals to invite them to take part in market research.
  • Where other lawful basis are inapplicable, we may rely on your consent for the use of your data. This applies in particular
    • where we process your health data such as details of medications you may be taking or your medical history.
  • For purposes which are required by law:
    • In response to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this policy.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing/newsletters without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

Who will we share this data with, where and when?

We share your personal data:

  • with service providers, suppliers, partners, sponsors, agents and representatives we have engaged to perform business-related functions on our behalf. For example, to: (a) conduct research and analytics; (b) create content; (c) provide customer support services; (d) conduct or support marketing; (e) fulfil orders; (f) handle payments; (g) host Services; (h) administer contests; (i) maintain databases; and (j) for accounting purposes;
  • in response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request;
  • with third parties if this will help us to enforce our policies and terms of use, to check for potential illegal activity (such as copyright infringement or fraud) or to protect the safety of other users of the Services; and
  • if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets.

Your personal data will not be transferred outside of the European Economic Area. To allow the smooth running of our Services we do need to transfer your personal data internationally.

Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules.

Children’s Privacy

We may collect personal data from children under the age of 13 where the child is using our Services.. Where personal data is processed for children under the age of 13, we obtain parental consent where required by law.

What rights do I have?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the contact details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

Where we require your personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us.

Cookies

What cookies will be used on the website?

The website uses (first party and third party) cookies (small files placed on website users’ hard drive) to distinguish you from other users of the website. This helps us to provide you with a high quality experience when you browse the website and also allows us to improve the website. We use cookies to analyse the flow of information; customise the services, content and advertising; measure promotional effectiveness; and promote trust and safety.

Our websites use the following types of cookies:

  • Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the websites and use their features, such as accessing secure areas of the websites. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.
  • Performance Cookies: These cookies collect information about how visitors use the websites, so that we can analyse traffic and understand how our visitors use our websites. We may use third party service providers for this purpose who may use their own cookies. These cookies don’t collect information that identify an individual visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the sites work.
  • Functionality Cookies: These cookies allow our sites to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
  • Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our sites or you link your account or engage with our content on or through a social media site such as Facebook or Twitter. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
  • Advertising Cookies: Some of our websites may use a third party advertising network to deliver targeted advertising.  These may also have the capability to track your browsing across different websites.  If you would like more information on targeted advertising and how to opt out of it, please visit www.youronlinechoices.com.
  • Google Analytics Cookies: These cookies are used by Google Analytics, which monitors traffic levels, search queries and visits to our websites. Google Analytics stores internet protocol (“IP”) addresses on its servers in the US. An IP address is a unique number assigned to each device (such as your computer) that allows it to communicate with other devices on a computer network (such as modems, printers or other computers). Neither BeSophro nor Google associate your IP address with any information that can identify the user personally. These cookies enable Google to determine whether you are a return visitor to the site, and to track the pages that you visit during your session. For more information about Google analytic cookies, please see Google’s privacy policy. Google have developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). If you want to opt out of Google Analytics, you can download and install the add-on for your web browser here.

If you don’t want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings or mobile device settings. The procedure for doing so varies from one browser application to another.  If you wish to reject cookies from our Websites, but wish to accept those from other Websites, you may be able to choose the option in your browser settings to receive a notice before a cookie is stored on your device.  Please consult the “Help” section of your browser or device for more information.

If you would like to opt out of third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

By disabling cookies, you may be prevented from accessing some features of our sites or certain content or functionality may not be available.

How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with us using the contact details below.

How long will you retain my data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Updates & effective date

From time to time, we may update this policy. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Service. We encourage you to periodically check back and review this policy so that you know what personal data we collect, how we use it, and with whom we share it.

Who is my data controller?

The data controller for your personal data is BeSophro Limited which you have a relationship or which manages the website you have visited and whose contact details are:

BeSophro Limited
Kingyo Therapy Suites,
58 South Molton Street,
W1K 5SL
Email: [email protected]
Tel no.: +44 (0)20 7813 6523

The policy posted on this Service was updated in October 2019.