Cookie Policy for The Wells Clinic Ltd

Owner contact email: info@thewellsclinic.com

Overview

This document informs Users about the technologies that help www.thewellsclinic.com to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with www.thewellsclinic.com.

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For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.

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For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

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Some of the purposes for which Trackers are used may also require the User's consent.

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Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

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Www.thewellsclinic.com uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.

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The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.

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In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting the Owner.

Activities strictly necessary for the operation of www.thewellsclinic.com and delivery of the Service

Www.thewellsclinic.com uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Third-party trackers

Platform services and hosting

These services have the purpose of hosting and running key components of www.thewellsclinic.com, therefore allowing the provision of www.thewellsclinic.com from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

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Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

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Webflow (Webflow, Inc.)

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Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host www.thewellsclinic.com. Webflow is highly customisable and can host websites from simple blogs to complex e-commerce platforms.

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Personal Data processed: Trackers and Usage Data.

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Place of processing: United States – Privacy Policy – Opt out.

Traffic optimisation and distribution

This type of service allows www.thewellsclinic.com to distribute their content using servers located across different countries and to optimise their performance.

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Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between www.thewellsclinic.com and the User's browser.

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Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

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Cloudflare (Cloudflare Inc.)

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Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.

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The way Cloudflare is integrated means that it filters all the traffic through www.thewellsclinic.com, i.e., communication between www.thewellsclinic.com and the User's browser, while also allowing analytical data from www.thewellsclinic.com to be collected.

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Personal Data processed: Trackers.

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Place of processing: United States – Privacy Policy.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on www.thewellsclinic.com in a centralised fashion.

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This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

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Google Tag Manager (Google Ireland Limited)

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Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Trackers.

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Place of processing: Ireland – Privacy Policy.

Other activities involving the use of Trackers

Measurement

Www.thewellsclinic.com uses Trackers to measure traffic and analyse User behaviour with the goal of improving the Service.

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

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Google Analytics 4 (Google Ireland Limited)

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Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of www.thewellsclinic.com, to prepare reports on its activities and share them with other Google services.

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Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

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In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

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Personal Data processed: browser information, city, device information, number of Users, session statistics, Trackers and Usage Data.

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Place of processing: Ireland – Privacy Policy – Opt Out.

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Storage duration:

• _ga: 2 years
• _ga_*: 2 years

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Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

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Hotjar is an analytics service provided by Hotjar Ltd.

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Hotjar honours generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

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Personal Data processed: Trackers and Usage Data.

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Place of processing: Malta – Privacy Policy – Opt Out.

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Storage duration:

• _hjAbsoluteSessionInProgress: 30 minutes
• _hjCachedUserAttributes: duration of the session
• _hjClosedSurveyInvites: 1 year
• _hjDonePolls: 1 year
• _hjFirstSeen: duration of the session
• _hjIncludedInPageviewSample: 30 minutes
• _hjIncludedInSessionSample: 30 minutes
• _hjLocalStorageTest: duration of the session
• _hjMinimizedPolls: 1 year
• _hjRecordingEnabled: duration of the session
• _hjRecordingLastActivity: duration of the session
• _hjSession*: 30 minutes
• _hjSessionRejected: duration of the session
• _hjSessionResumed: duration of the session
• _hjSessionTooLarge: 1 hour
• _hjSessionUser*: 1 year
• _hjShownFeedbackMessage: 1 year
• _hjTLDTest: duration of the session
• _hjUserAttributesHash: duration of the session
• _hjViewportId: duration of the session
• _hjid: 1 year

Heat mapping and session recording

Heat mapping services are used to display the areas of www.thewellsclinic.com that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour.
Some of these services may record sessions and make them available for later visual playback.

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Hotjar Heat Maps & Recordings (Hotjar Ltd.)

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Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.

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Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers.

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Find Hotjar’s opt-out information here.

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Personal Data processed: Trackers, Usage Data and various types of Data as specified in the privacy policy of the service.

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Place of processing: Malta – Privacy Policy – Opt Out.

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Storage duration:

• _hjAbsoluteSessionInProgress: 30 minutes
• _hjCachedUserAttributes: duration of the session
• _hjClosedSurveyInvites: 1 year
• _hjDonePolls: 1 year
• _hjFirstSeen: duration of the session
• _hjIncludedInPageviewSample: 30 minutes
• _hjIncludedInSessionSample: 30 minutes
• _hjLocalStorageTest: duration of the session
• _hjLocalStorageTest: duration of the session
• _hjMinimizedPolls: 1 year
• _hjRecordingEnabled: duration of the session
• _hjRecordingLastActivity: duration of the session
• _hjSession*: 30 minutes
• _hjSessionRejected: duration of the session
• _hjSessionResumed: duration of the session
• _hjSessionTooLarge: 1 hour
• _hjSessionUser*: 1 year
• _hjShownFeedbackMessage: 1 year
• _hjTLDTest: duration of the session
• _hjUserAttributesHash: duration of the session
• _hjViewportId: duration of the session
• _hjid: 1 year

Targeting & Advertising

Www.thewellsclinic.com uses Trackers to deliver personalised marketing content based on User behaviour and to operate, serve and track ads.

Advertising

This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on www.thewellsclinic.com, possibly based on User interests.

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This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

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Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside www.thewellsclinic.com. For more information, please check the privacy policies of the relevant services.

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Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

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Google Ad Manager (Google Ireland Limited)

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Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.

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In order to understand Google's use of Data, consult Google's partner policy.

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This service uses the “DoubleClick” Cookie, which tracks use of www.thewellsclinic.com and User behaviour concerning ads, products and services offered.  

Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

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Personal Data processed: Trackers and Usage Data.

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Place of processing: Ireland – Privacy Policy.

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Storage duration:

• AID: 2 years
• ANID: 2 years
• Conversion: 3 months
• DSID: 14 days
• FCNEC: 1 year
• FLC: 10 seconds
• FPAU: 3 months
• FPGCLAW: 3 months
• FPGCLDC: 3 months
• FPGCLGB: 3 months
• IDE: 2 years
• NID: 6 months
• RUL: 1 year
• TAID: 14 days
• __gads: 2 years
• __gsas: 2 years
• _gac_: 3 months
• _gac_gb_: 3 months
• _gcl_au: 3 months
• _gcl_aw: 3 months
• _gcl_dc: 3 months
• _gcl_gb: 3 months
• _gcl_gf: 3 months
• _gcl_ha: 3 months
• id: 2 years
• test_cookie: 15 minutes

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Meta Audience Network (Meta Platforms Ireland Limited)

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Meta Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Meta's use of Data, consult Meta's data policy.

Www.thewellsclinic.com may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

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Personal Data processed: Trackers, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

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Place of processing: Ireland – Privacy Policy – Opt out.

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Meta Lookalike Audience (Meta Platforms Ireland Limited)

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Meta Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Meta's Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the basis of their past use of www.thewellsclinic.com or engagement with relevant content across Meta's apps and services.

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On the basis of these Data, personalised ads will be shown to Users suggested by Meta Lookalike Audience.

Users can opt out of Meta's use of Trackers for ads personalisation by visiting this opt-out page.

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Personal Data processed: Trackers and Usage Data.

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Place of processing: Ireland – Privacy Policy – Opt out.

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Storage duration:

• _fbp: 3 months

User database management

his type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to www.thewellsclinic.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving www.thewellsclinic.com.

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Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on www.thewellsclinic.com.

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Intercom (Intercom Software UK Limited)

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Intercom is a User database management service provided by Intercom Software UK Limited.

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Intercom can also be used as a medium for communications, either through email, or through messages within www.thewellsclinic.com. Intercom Messenger may use Trackers to recognise and track Users behaviour.

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Personal Data processed: Data communicated while using the service, email address, Trackers, Universally unique identifier (UUID), Usage Data and various types of Data as specified in the privacy policy of the service.

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Place of processing: United Kingdom – Privacy Policy.

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Storage duration:

• intercom-id-*: 10 months
• intercom-session-*: 7 days
• intercom-test: indefinite

How to manage preferences and provide or withdraw consent

There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:

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Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.

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Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.

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It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.

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Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

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With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.

Locating Tracker Settings

Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

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• Google Chrome
• Mozilla Firefox
• Apple Safari
• Microsoft Internet Explorer
• Microsoft Edge
• Brave
• Opera

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Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).

How to opt out of interest-based advertising

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

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The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Consequences of denying consent

Users are free to decide whether or not to grant consent. However, please note that Trackers help www.thewellsclinic.com to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, in the absence of the User's consent, the Owner may be unable to provide related features.

Owner and Data Controller

The Wells Clinic, Robert Denholm House, Bletchingley Road, Nutfield, England, RH1 4HW

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Owner contact email: info@thewellsclinic.com

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Since the use of third-party Trackers through www.thewellsclinic.com cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

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Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by www.thewellsclinic.com.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through www.thewellsclinic.com (or third-party services employed in www.thewellsclinic.com), which can include: the IP addresses or domain names of the computers utilised by the Users who use www.thewellsclinic.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using www.thewellsclinic.com who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of www.thewellsclinic.com. The Data Controller, unless otherwise specified, is the Owner of www.thewellsclinic.com.

www.thewellsclinic.com (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by www.thewellsclinic.com as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

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This privacy policy relates solely to www.thewellsclinic.com, if not stated otherwise within this document.