This is the Privacy & Cookies Policy (the ‘Policy’) of BBE Health Limited (trading as The Well HQ), a company incorporated under the laws of England and Wales with company number 12845825 whose registered office is at 3rd Floor, 16-17 West Street, Brighton, BN1 2RL (hereafter ‘The Well HQ’, ‘we’ or ‘us’). This Policy describes the ways in which The Well HQ collects and uses information about you when you use our website at https://www.thewell-hq.com/ (the “Website”), or when you enrol (subject to separate terms and conditions) to participate in any of our courses (each a “Course”).

The Well HQ may change this Policy at any time and when this happens we will notify you of any changes to this Policy by noting this on the Website or, if you are enrolled on any Course, we will email you. The changes will apply to your use of the Website and/or your participation in a Course after we have notified you. If you do not wish to accept the new Policy you should stop using the Website and/or participate in the Course (as applicable). If you continue to use the Website and/or participate in any Course after the changes, your continued use of the Website and/or your participation in such Course shows us your agreement to be bound by the new Policy.

This Policy was last changed in September 2023.

1. ICO registration

For the purposes of data protection legislation, The Well HQ is the controller for the processing of your personal data and has registered with the Information Commissioner’s Office (“ICO”). The Well HQ’s registration number is ZB125486.

2. Information we use about you

We collect and process the following information from you on the Website:

3. Sharing your information with third parties

Some of the information The Well HQ collects from you is passed to third parties. These third parties are:

• our website hosting provider – Bluehost;
• our platform providers – such as WordPress, LearnDash amd bbPress;
• our payment provider – WooCommerce;
• marketing providers, such as Kajabi Service and Zapier;
• our security and malware protection provider – Wordfence and Google CAPTCHA;
• our analytics providers – Google Analytics and Meta;
• certain third party analytics and cookies providers as described further in Clause 7 below;
• our regulator (the ICO);
• in anonymised form, The Well HQ may share the information with:
  1. any third party, in relation to the sale of some or all of The Well HQ’s business, or its assets, or as part of any business restructuring or reorganisation. The Well HQ will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred under these circumstances;
  2. data aggregators and platform providers as part of an analysis of user metrics or sales performance; or
• law enforcement agencies in compliance with law enforcement.

4. Links to third party websites and third party adverts

The Well HQ is not responsible for the privacy policies and practices of other sites even if you access them via the Website and/or as part of your participation in any Course. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

5. Security

The Well HQ has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.

6. Storage and Data Retention

We store your personal data in the USA. Where we (or our processor) transfer personal data outside the EEA or UK we ensure that we (or our processor) have an appropriate adequacy ground to do so e.g., SCCs. We retain your personal data for no longer than is reasonable in line with the purposes for which it was originally collected.

7. Cookies

What are Cookies

Cookies are small text files that are placed on your device when you use the Website and/or participate in any Course. The Well HQ’s use of cookies is detailed below. Session cookies enable you to move from page to page within the Website and/or participate in any Course and any information you enter will be remembered but is deleted when you close the page on that Website or after a short time. Persistent cookies allow us to remember your preferences and settings when you use the Website and/or participate in any Course in the future.

Disabling Cookies

The use of the cookies described above improves the functionality of our Website and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on the Website or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Website, and some of the features of the Website may not function properly.

Third Party Cookies

Third Party advertisers may place or read cookies on your browser or device when you use the Website and/or participate in any Course. This Policy is applicable only to the use of cookies by The Well HQ and does not cover the use of cookies by any third parties (including advertisers or social media companies).

More information

To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit aboutcookies.org or www.allaboutcookies.org.

8. Exercising your rights

You can contact us using the details set out in Clause 9 below if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data.

9. The Well HQ Details

If at any time you would like to contact The Well HQ about your views on this Policy or any enquiry relating to your personal information, you can do so by sending an e-mail to us at hello@thewell-hq.com or write to us at “Data Protection Query, BBE Health Limited (t/a The Well HQ), 3rd Floor, 16-17 West Street, Brighton, BN1 2RL”. You also have the right to make a complaint to the ICO by contacting them at any time.