Your privacy

Your privacy is important to us. It is our policy to respect your privacy and comply with all applicable laws and regulations regarding any personal information we may collect about you, including across our website, www.thefullerlife.co.uk, other sites we own and operate, and our email services.

This Privacy Policy will inform you as to how we process your information when you engage with us and tell you about your privacy rights and how the law protects you. Please read this Policy along with our Terms of use.

Please note that the name of the specific entity that processes your personal information will depend on the specific services you use, and we will duly inform you of the relevant entity that will be the contracting party. By using our website and transacting with us, you are accepting the terms of this Privacy Policy.

This policy is effective as of 10 August 2021 and was last updated on 10 August 2021.

Who we are

The Fuller Life LLP is the Responsible Party in the United Kingdom and our partner company in South Africa, The Fuller Life (Pty) Ltd, is the Responsible Party there, collectively referred to as "The Fuller Life", "we", "us" or "our" in this Privacy Policy.

Responsible Party: This is the entity that, alone or in conjunction with others, determines the purpose of and means for processing Personal Information. For purposes of the applicable Data Protection Laws, we are the "data controllers". This means that we determine the purposes for which and the manner in which your Data is processed.

Our Information Officer responsible for overseeing questions in relation to our information processing and protection can be contacted by emailing privacy@thefuller.life.

Scope of this Policy

This Privacy Policy applies only to the actions of The Fuller Life and Users with respect to our own websites and communications. Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

As a Limited Liability Partnership, we are not responsible for the services offered or the information collected by independent partners via their own third-party websites or email services, nor are we responsible for their compliance with applicable legislation. These other sites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We cannot be held responsible for any wrongful handling of end users' information by other sites. Please refer to the privacy policies of these websites and/or communications if you have any queries or disputes.

Information we collect

Information we collect includes both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services.

Log Data
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device's Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, other details about your visit, and technical details that occur in conjunction with any errors you may encounter. Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Personal Information
We may ask for personal information which may include one or more of the following:

• Identity Data includes first name, last name, age, nationality, username or similar identifier, job title, date of birth and gender;
• Contact Data includes billing address, physical address, email address, telephone numbers and details of your public social media profiles;
• Instruction Data is Personal Information that may form part of correspondence, documents or other materials that we process in the course of our services;
• Financial Data includes banking details and/ or payment card details;
• Transaction Data includes details about payments to and from you and other details of Services you have accessed on our website;
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
• COVID-19 Data includes the prescribed questions we may ask as required by regulations and to ensure a safe and healthy environment, such as whether you have any symptoms or have been in contact with someone who had tested positive for COVID-19.

Collection and use of information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

We may collect Personal Information from you when you do any of the following:

• Interact directly with us in person, via digital conferencing, chat or telephone

• Complete a contact request form on one of our website pages

• Sign up to receive updates from us via email or social media channels

• Use a mobile device or web browser to access our content

• Contact us via email, social media, or on any similar technologies

• When you mention us on social media

• Give us feedback

We may also receive Personal Information about you from third parties or publicly available sources, such as Technical Data from analytics providers like Google, advertising networks and Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Where card payments are processed online using a PayPal gateway (indicated by the PayPal logo), PayPal is an independent Controller in respect of all Personal Information processed in connection with the payment processing services, as described in PayPal's privacy policy.

We will collect your data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the website, see the section below, headed "Cookies".

Submission of Personal Information on behalf of another: If you provide information on behalf of someone else, then it is your responsibility to obtain the necessary consent from the person/user before making the Personal Information available to us. On receipt of Personal Information, we assume that the necessary consent has been obtained and will process the Personal Information as per your instructions. By submitting such Personal Information on behalf of another person/user, you indemnify us against any claim relating to Personal Information that has been processed without the necessary consent or other available exception allowed by law.

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to enable you to customise or personalise your experience of our website

• to contact and communicate with you

• for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms

• for advertising and marketing, including sending you promotional information about our products and services and information about third parties that we consider may be of interest to you

• for internal record keeping and administrative purposes

• to offer additional benefits to you

• to comply with our legal obligations and resolve any disputes that we may have

• for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use

For the delivery of direct marketing to you via email: We'll need your consent, whether via an opt-in or soft-opt-in:

• Soft opt-in consent applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt out.

• For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.

Security of your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach as soon as reasonably possible where we are legally required to do so.

Where use of our Services requires an account, you agree to provide us with complete and accurate information when you register for one. You are responsible for selecting a secure password and you are liable for any activity that occurs under your account. You must keep your account information up-to-date and your password secure and notify us immediately of any unauthorized uses of your account or upon becoming aware of any other breach of security.

How long we keep your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this Privacy Policy. If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children's privacy

We do not aim any of our products or services directly at children under the age of 18, and we do not knowingly collect personal information about children under 18.

Disclosure of Personal Information to Third Parties

We may disclose personal information to internal third parties, including members of our limited liability partnership, subsidiaries or affiliates of our company; third-party service providers for the purpose of enabling them to provide their services, for example, IT service providers, data storage, hosting and server providers, advertisers, or analytics platforms; our employees, contractors, and/or related entities; our existing or potential agents or business partners; courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights; third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you; third parties to collect and process data.

International Transfers of Personal Information

The personal information we collect is stored and/or processed where we or our partners, affiliates, and third-party providers maintain facilities, which means we may transfer your Personal Information to recipients outside the Republic of South Africa and/or outside of the United Kingdom. Please be aware that the locations to which we store, process, or transfer your personal information may not have the same Data Protection Laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

Applicable Data Protection Laws: Any law relating to the processing of personal data, including but not limited to the South African Protection of Personal Information (POPI) laws; Directive 96/46/EC (Data Protection Directive) and any national implementing laws, regulations and secondary legislation, for as long as the European Union General Data Protection Regulation (GDPR) is effective in the UK.

We will only transfer your Personal Information to countries that have appropriate data protection and privacy legislation to protect your Personal Information.

Your Rights and Controlling Your Personal Information

You always retain the right to withhold Personal Information from us, with the understanding that your experience of our website may be affected.

Request access: You retain the right to request details of any Personal Information we hold about you and to check that we are lawfully processing it.

• Opt out: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email database or opt out of communications. Please be aware we may need to request specific information from you to help us confirm your identity. Where you opt out of receiving marketing messages, we will remove you from our mailing list. However take note that we will continue to use your Personal Information in ways that are reasonably necessary to provide our services to you, as stated above.
  
• Rectification and erasure: You can ask us for, where necessary, the correction, destruction or deletion of your personal information.
  
• Right to restrict or object: You have the right to "block" us from using your Personal Information or limit the way in which we can use it. You can also object to our use of your Personal Information including where we use it for our legitimate interests.
  
• Right to data portability: You can request that we move, copy or transfer your Data.
  
• Make a complaint: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint. 

In South Africa, the Information Regulator's office (IR) (https://www.justice.gov.za/inforeg/).
In the United Kingdom, the Information Commissioner's Office (ICO) (https://ico.org.uk).

Use of Cookies

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data that our websites store on your computer, and access each time you visit, so we can understand how you use our sites. This helps us serve you content based on preferences you have specified and to improve our range of services.

Our use of Cookies complies with current UK and EU Cookie Law, as well as the laws of the Republic of South Africa.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling The Fuller Life to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the website may not function fully or as intended.

We may place the following Cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.

Our websites may serve ads from third-party vendors:

• Third-party vendors, including Google, use cookies to serve ads based on a user's prior visits to this Website or other websites;

• Google's use of advertising cookies enables it and its partners to serve ads to you based on your visit to this Website and/or other sites on the Internet;

• You may opt out of personalized advertising by visiting Ads Settings. (Alternatively, you can opt out of a third-party vendor's use of cookies for personalized advertising by visiting aboutads.info).

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to https://aboutcookies.org/. You will also find details on how to delete cookies from your computer.

Changes of business ownership and control

The Fuller Life may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of The Fuller Life. Data provided will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally supplied to us. We may also disclose data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Acceptance of This Policy

By accepting this Privacy Statement, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms. You further acknowledge that we may disclose your personal information within The Fuller Life group of companies, and you expressly consent to this.

Contact Us

If you have any questions or concerns based on this Privacy Policy or regarding the way in which we handle personal information, please contact us at privacy@thefuller.life.