I. Introduction & Definitions
By using or accessing the Wellnesspatron.com Services you agree to these Terms, according to their latest updated version.
You acknowledge that by providing your personal data to us, you consent to its processing in the manners outlined below. When providing personal data about others, you confirm that you have the consent of these individuals to supply their personal data. We are unable to offer you any product or Service that requires the processing of special category personal data, as defined in the General Data Protection Regulation (GDPR) unless you provide explicit consent for the collection and use of such data.
“we”, “us”, “our”, “WellnessPatron”, “Wellnesspatron.com” refers to Wellnesspatron.com, a website managed by Keller Media OÜ, a company registered in Estonia, with a registered address of A. H. Tammsaare tee 47, 11316, Tallinn, Estonia. Keller Media OÜ is registered under the registration code 12618219 and is a VAT liable company with a VAT registration code EE101749943.
“you” and “your” means the person who accesses and uses our Site.
I. Information we collect
Information we may collect directly from you
We may collect information directly from you when you use our Services — for example, when you register an account, when you request information, when you request to contact us, when you use interaction points such as forms or other fields on our Site. In such cases, we may ask you to provide us with one or more of the following pieces of information:
- Email address
- Age, gender, or other demographic information
- Personal responses, emails, replies, or other User Generated Content (UGC)
When this data is collected
We may collect your personal data when:
- You insert any data on our user interface, such as by filling our search bars or forms
- You make customer enquiries via email or other means of communication
- You register for information or other Services
- You respond to communications or surveys
- We require additional information from you for validation purposes
- When you create any User Generated Data on our site, including but not limited to giving ratings, writing reviews, comments and in general engaging in any activity on our Forum.
Information automatically collected
Types of Information Collected
When you visit the Site, use the Services, or open an email from Wellnesspatron.com, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation:
- IP address or other device address or ID.
- Web browser and/or device type.
- Geolocation data, including if you use the Site on a mobile device.
- Hardware and software settings and configurations.
- Web pages or sites that you visit just before or just after visiting the Site.
- Pages you view on the Site.
- Your actions on the Site.
- Dates and times that you visit, access, or use the Services.
General Cookies description
When you use the Services, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. If you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.
Typically, they only contain two pieces of information; a site name and a unique user I.D.
We also use non-essential cookies, (also mentioned as “additional cookies”) – that help us to improve our online marketing and advertising efforts, and to further optimize your user experience on our Site. These cookies allow us to track your user actions and associate them with anonymous user data, with the assistance of 3rd parties and services such as Google Ads, Google Adsence, Google Analytics, DoubleClick, Bing Ads, Google Tag Manager, Facebook, YouTube etc. We can use those data to optimize and even customize the service that we provide to you, and provide you with more relevant results and services. We may also use those data to find people with similar interests and actions to you, also known as lookalike audiences. We may also use those data to enhance our business operations, offerings, and profitability.
All cookies can be disabled using the information given in the section below titled “How do I manage my cookies”. It should be noted that if you choose to remove or disable all cookies, this may harm the way the website is intended to operate and result in reduced or inaccurate functionality.
Types of cookies we may use
This a list of cookies that our site may use, but not limited to
User action cookies
Allows our web servers to respond to your actions on the Site e.g. logging in, entering user preferences on search bars, customizing interests or any other interactive interface available on our site, etc.
Allows us to remember your preferences e.g. saving you the trouble of typing in your user information every time. This includes your cookie settings preferences.
Allow us to track your actions in our Site and pass on information on inbound and outbound links and other 3rd parties you may visit and interact with. They also allow us to track your user-generated data actions. Those cookies usually include GTM (Google Tag Manager) tags, loan tags, URL tags, attribution tags, or UGC related tags.
Interaction and Conversion cookies
Other marketing cookies
Third-party cookies that show us how you found our Site and which Site you came from, as well as analyse your behavior and actions within our Site. This helps us know how effective our online marketing is. Some may also allow us to create more targeted user audiences based on past user actions or create similar audiences (also known as lookalikes) that are based on current user behaviors and demographics to allow us to reach more potential users and customers. They also allow us to reward some external sites for directing you to us. Those third parties may include Google Ads, Google AdSense, Google Analytics, Bing Ads, Yahoo, Facebook, Amazon, Pepperjam/Ascend, or others.
How do I manage my cookies?
Most browsers let you manage and block cookies from specific sites. You also have the option of only blocking third-party cookies, which still lets you get the best experience when using wellnesspatron.com. You can find out how to manage your browser cookie settings here.
For additional information about how to manage and disable cookies you can visit https://www.allaboutcookies.org/. However, please note that by deleting or disabling cookies this could affect the functionality of our Site and you may not be able to access certain areas or features of our site. We do not operate, neither partner with the owner of this website, while only consider it a good collection of data regarding cookies in a user-friendly form. We do not bear any responsibility for any action resulting from your use or non-use of the information posted on this website, as well as for the accuracy or completeness of any information thereto.
Also, you can disable specific cookies related to Google & Facebook ads as shown here:
You may also read Facebook’s policy here.
Third-Party Web Beacons and Buttons
We may implement third-party advertising or other content on the Site that may use web beacons, which allow the third-party content provider to read and write Cookies to your web browser in connection with your viewing of the third-party content on the Site. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser cookies, even when you do not interact with the button.
Several different targeting and advertising programs may be used on this Site, including without limitation Google Analytics. We allow third parties, including affiliated and non-affiliated businesses, advertising networks, analytics providers, and other advertising service providers to collect information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. These third parties may use this information to display online advertisements across your browsers and devices, tailored to your interests and preferences.
Information collected through web beacons, buttons, and similar technologies is collected directly by third parties, and we are not responsible for the privacy practices of these third parties. The information collected by these third parties in this manner is subject to that third party’s own privacy policies. Some of these third parties are members of the Network Advertising Initiative and participate in the industry’s opt-out, available at http://optout.aboutads.info/#!/ or at http://optout.networkadvertising.org/#!/.
Additionally, you may opt-out of the use of Google Analytics Cookies here: https://tools.google.com/dlpage/gaoptout.
Information from other sources
II. How We Use Your Information
Your information is an integral part of our operations, and we use it in a variety of ways in providing the Services and operating our business. We use the information you provide, for example:
- To provide you the Services you request and enable third parties to provide additional services to you. This may include marketing services that display advertising content to you, using a variety of media including -but not limited to- the Wellnesspatron.com website, email, and notifications.
- To operate, maintain and improve the Services and create new features and functionality.
- To understand and analyse usage trends and preferences of our users across different devices.
- For fraud detection and information security.
- We may use your e-mail address or other personal information (a) to contact you for administrative purposes such as customer service, (b) to address intellectual property, right of privacy or defamation issues related to content you have posted on the Services, and/or (c) to send you promotional materials, offers, and/or messages related to the Services and the activities of third parties we work with. Generally, you can opt-out of receiving promotional communications, through links provided in the messages, by updating your account preferences through the Services, or by contacting us directly at [email protected].
- We may use Cookie Information and Automatically Collected Information to: (a) personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) provide customized advertisements, content, and information across your devices; (c) monitor and analyze the effectiveness of Services and third-party marketing activities; (d) monitor aggregate site usage metrics such as the total number of visitors and pages viewed; and (e) track your entries, submissions, and status in any promotions or other activities.
- There are certain circumstances where we process your personal data for our legitimate business interests. These can be commercial or societal benefits and for us to process your data, we will always balance our interests against your own to ensure it is fair.
The following processes rely on legitimate interest:
- Sharing data with our suppliers and Service providers in order to generate a service request of yours
- Fraud detection and prevention
- Engaging and contacting you throughout the lifecycle of your wellnesspatron.com account to ensure you have a good experience as a valued user.
- Engaging you and contacting you to remind you of our Service
- Internally auditing our processes to maintain our high standards
- Providing a summary of our Service
- Sharing data with selected third parties in order to add value to our products
- We also engage in online advertising, to keep you aware of what we’re up to and to help you see and find our Services.
III. How We Share Your Information
- We may disclose your information in connection with providing the Services and the operation of our business. For example, we may share personal information, such as name, email, address, and other identifying information, with third-party service providers to verify your identity in connection with your use of certain aspects of the Services.
- We may share information collected directly from you with third-party partners or third-party service providers in connection with your use of specific aspects of the Services. Some examples include but are not limited to:
- When you request to learn more information for a product on our Site.
- When you request additional or personalized information regarding our Service
- When you report a complaint about a product, or a third-party partner featured on our Site we may forward your complaint to that partner.
- When you request answers or advice through our Services, wellnesspatron.com may provide certain of your information to third party companies, advocates, and advisors.
- We may share automatically collected information such as IP address as well as de-identified information with third-party advertising partners when you leave our Site to go to a third-party site to request information or purchase products.
- We may share your information with third-party service providers to support our internal and business operations. In such cases, service providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure. For example:
- For Site or application development, hosting, data storage, maintenance, and other services for us.
- For internal marketing, delivery of emails, including promotional, marketing, and transactional materials, delivery of other promotional materials, including via postal mailers, SMS and text messaging, and online and social media promotions and advertising.
- For fraud prevention and security purposes.
- When you choose to share your own information on a publicly accessible area of the Site, such as a public profile page or any section where you can publicly submit questions to us or our third-party partners, that information will be available to anyone who is able to access that content, including other Site users. Additionally, questions you submit, and answers provided by third parties may be posted on our Site and viewable by other users and the public.
- We may share de-identified and/or aggregate analytics with third-party partners about how users interact with our Services, including usage patterns for certain programs, content, Services, advertisements, promotions, and/or functionality available through the Service.
- We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
- If you submit a request through our Services, a third-party service provider may directly contact you with relevant information via telephone, fax, and/or email. You may also receive telemarketing calls as a result of submitting the request, even if you are on the National Do Not Call Registry or any other similar registry.
You may, of course, decline to share certain information with us, in which case we may not be able to provide you with some of the features and functionality of the Services.
IV. Account information & Data Rights
You have the following rights when it comes to your account information or the data that is related to your use of the Service:
Updating your information
Once you have registered for a wellnesspatron.com account, you may update or correct your profile information and preferences at any time by accessing your account settings page through the Site.
Deactivating your account
We do not delete information about you upon deactivation of your account. Although your deactivated status is reflected promptly in our user databases, we may retain the information you submit for a variety of purposes, including legal compliance, backups and archiving prevention of fraud and abuse, and analytics. Upon deactivation, you will no longer receive emails from wellnesspatron.com and links to third-party accounts, and Services can automatically terminate.
Unsubscribing from emails
If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the Services) by using the unsubscribe process at the bottom of any marketing email from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. If you wish to be excluded from all other user databases as well wherever possible, please inform us at [email protected].
Request your data
In order to access the data, we hold about you, you need to make a ‘Subject Access Request’, or SAR. To make a SAR please email us at: [email protected].
- Your full name, physical address, email address, phone number
- Latest utility bill on your name verifying your physical address and phone number
- What information you would like to receive
Once we have received your written request and documents, we will have 30 calendar days to fulfill your request. Where for some reason this will not be possible, for instance, due to large volumes of data being involved, we are permitted by law to take up to an additional 60 days to fulfill your request. Where any such delay is anticipated we will inform you of this as soon as possible along with details of when we expect to be able to provide you with the requested documentation.
Retention of your data
Your personal data will be kept for as long as we require it in order to provide you with the agreed product(s) or Service(s), It will continue to be retained after any account or Service has been closed or otherwise come to an end in line with legal and regulatory requirements.
Cookie data has varying retentions times, depending on the settings provided by our 3rd party partners. In most cases, such as with session data provided by Google Analytics, cookie should not last more than 4 hours, unless if required for the continuation of the operation of the Service during extented user sessions.
Other data rights
Your other rights as a data subject, where applicable, include:
- The right to be informed about our processing of your personal data
- The right to have your personal data corrected if it is inaccurate, and to have incomplete personal data completed
- The right to object to the processing of your personal data
- The right to have your personal data erased (“right to be forgotten”)
- The right to move, copy, or transfer your personal data (“data portability”)
- Rights regarding automated decision-making, including profiling.
You may execute any of your rights as a data subject indicated above by contacting us via email:[email protected]. Please notice, when you choose to remove your personal data from our database, we shall also delete your account and suspend any Service. Within a certain period of time you may request to restore your account, however, in this case you grant us with the right to collect your personal data again.
To prevent abuse and/or misuse of the Service by a User following termination or deletion of an account, we shall retain such information as we deem in our sole discretion may be necessary to ensure that a User does not open a new account and profile in breach of our Terms and Conditions and to ensure compliance with all laws and regulations.
Notice: Even after we remove your personal data or delete your account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.
For more details on these rights and how to exercise them, please contact: [email protected].
If you have any queries about your data rights, or believe that they have not been met by Wellnesspatron.com, please contact our Data Protection Officer at [email protected].
V. Our Commitment to Data Security
General data policy code of conduct
We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services or store on the Site, and you do so at your own risk.
Confidentiality and disclosure of your data
We will endeavour to treat your personal data as private and confidential. From time to time we may employ agents and subcontractors to process your personal data on our behalf. The same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction.
We would like to bring to your attention our obligations to disclose data in the following four exceptional cases permitted by law, and the other situations set out below. These are:
- Where we are legally compelled to do so
- Where there is a duty to the public to disclose
- Where disclosure is required to protect our interest
- Where disclosure is made at your request or with your consent
If you make a complaint about the Service we have provided, we may be obliged to forward details about your complaint, including your personal data, to the relevant ombudsman. You can be assured that they are similarly obliged to adhere to the requirements of the GDPR and keep your personal data strictly confidential.
Please note that we and our suppliers may make several checks to assess an application for finance or verify identities to prevent and detect crime and money laundering, as well as data sharing at any time for the purposes of fraud prevention.
Fraud prevention and detection
In order to prevent and detect fraud, Services may at any time share information about you with members of wellnesspatron.com.
In addition, we actively monitor information entered into our Site and pass on intelligence of suspected fraud to other parties including fraud prevention agencies. Law enforcement agencies may access and use this information.
We and other organizations may also access and use this information to prevent fraud and money laundering, for example, when:
- checking details on applications for credit and credit-related or other facilities
- managing credit and credit-related accounts or facilities
- recovering debt
- checking details on proposals and claims for all types of Insurance
- checking details of job applicants and employees
We do Our best and implement every possible measure in order to be compliant with Privacy Protection laws, including General Data Protection Regulation (GDPR).
As per GDPR requirements Wellnesspatron.com ensures that at all times We will:
(a) Handle any personal data that comes into Our possession in the course of performing the Services in compliance with all relevant data protection and electronic privacy legislation, and
(b) Take all reasonable steps to safeguard such personal data.
By using Our Services you confirm that you have been notified about the collection of your personal data by Wellnesspatron.com and Our hosting services provider, and have received the following information:
(a) The identity and the contact details of the controller – Wellnesspatron.com and Keller Media OÜ.
(b) The contact details of the data protection officer: [email protected].
(c) The purposes of the processing for which the personal data are intended, as well as the legal basis for the processing;
(d) The recipients or categories of recipients of the personal data;
(e) The fact that the controller intends to transfer personal data to a third party (hosting services provider, partners).
Wellnesspatron.com uses hosting services from GoDaddy Operating Company, LLC, therefore your personal data becomes available to them.
You can familiarize yourself with the hosting services provider’s privacy protection policy by following this link.
Where personal data has not been obtained from the data subject Wellnesspatron.com will provide the data subject with the following information:
(a) The identity and contact details of the controller and, where applicable, of the controller’s representative;
(b) The contact details of the data protection officer, where applicable;
(c) The purposes of the processing for which the personal data is intended as well as the legal basis for the processing;
(d) The categories of the personal data concerned;
(e) The recipients or categories of recipients of the personal data, if any;
(f) Where applicable, the fact that the controller intends to transfer personal data to a third party, third country, or international organization.
You, as a data subject, shall have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data, and the following information:
(a) The purposes of the processing;
(b) The categories of personal data concerned;
(c) The recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations;
(d) Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f) The right to lodge a complaint with a supervisory authority;
(g) Where the personal data is not collected from the data subject, any available information as to their source.
We shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
(a) The pseudonymisation and encryption of personal data;
(b) The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(c) The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
(d) A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
We shall take steps to ensure that any natural person acting under the authority of Wellnesspatron.com, who has access to personal data does not process it except on instructions from Wellnesspatron.com unless they are required to do so by law.
Wellnesspatron.com will only process any personal data on your written instruction, unless otherwise required by law. In this event, Wellnesspatron.com will tell you what We are required to do by law before We do it. Wellnesspatron.com will keep records of Our processing activities during the term of your use of the Services.
Wellnesspatron.com shall immediately notify the data subject about any personal data breach and take appropriate steps to minimize the harm from such a breach
Complain to the Supervisory Authority
If you have any complaints relating to the processing of your personal data, you also have the right to complain to the relevant Supervisory Authority.
VII. Our Contact Information
If you have any further questions, don’t hesitate to contact us. You can email us at [email protected]
Date of Revision