We care about your privacy

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

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Owner contact email: info@thewellsclinic.com

Types of Data collected

Among the types of Personal Data that www.thewellsclinic.com collects, by itself or through third parties, there are: Usage Data; Trackers; first name; last name; phone number; email address; number of Users; city; device information; session statistics; browser information; payment info; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Data communicated while using the service.

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Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

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Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using www.thewellsclinic.com.

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Unless specified otherwise, all Data requested by www.thewellsclinic.com is mandatory and failure to provide this Data may make it impossible for www.thewellsclinic.com to provide its services. In cases where www.thewellsclinic.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

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Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

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Any use of Cookies – or of other tracking tools – by www.thewellsclinic.com or by the owners of third-party services used by www.thewellsclinic.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

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Users are responsible for any third-party Personal Data obtained, published or shared through www.thewellsclinic.com and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

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The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of www.thewellsclinic.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

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• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

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Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

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Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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Therefore:

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• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

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The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

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Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Platform services and hosting, Contacting the User, Traffic optimisation and distribution, Analytics, Access to third-party accounts, Advertising, Handling payments, Heat mapping and session recording, Hosting and backend infrastructure, Infrastructure monitoring, Tag Management and User database management.

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For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

This type of service allows www.thewellsclinic.com to access Data from your account on a third-party service and perform actions with it.These services are not activated automatically, but require explicit authorisation by the User.

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Stripe account access (Stripe Payments Ltd)

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This service allows www.thewellsclinic.com to connect with the User's account on Stripe, provided by Stripe, Inc.

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Personal Data processed: email address; first name; last name; payment info.

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Place of processing: United Kingdom – Privacy Policy.

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.
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.  

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

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Personal Data processed: Trackers; Usage Data.

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Place of processing: Ireland – Privacy Policy.

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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); 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.

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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; Usage Data.

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

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; Usage Data.

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

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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; Usage Data.

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

Contacting the user

Contact form (www.thewellsclinic.com)

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By filling in the contact form with their Data, the User authorises www.thewellsclinic.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

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Personal Data processed: email address; first name; last name; phone number.

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Mailing list or newsletter (www.thewellsclinic.com)

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By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning www.thewellsclinic.com.

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Your email address might also be added to this list as a result of signing up to www.thewellsclinic.com or after making a purchase.

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Personal Data processed: email address; first name; last name; phone number.

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Phone contact (www.thewellsclinic.com)

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Users that provided their phone number might be contacted for commercial or promotional purposes related to www.thewellsclinic.com, as well as for fulfilling support requests.

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Personal Data processed: phone number.

Handling payments

Unless otherwise specified, www.thewellsclinic.com processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Www.thewellsclinic.com isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

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Stripe (Stripe Payments Ltd)

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Stripe is a payment service provided by Stripe Payments Ltd.

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Personal Data processed: email address; first name; last name.

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Place of processing: United Kingdom – Privacy Policy.

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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. Find Hotjar’s opt-out information here.

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Personal Data processed: Trackers; Usage Data; 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.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable www.thewellsclinic.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of www.thewellsclinic.com.

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Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

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Amazon Web Services (AWS) (Amazon Web Services, Inc.)

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Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

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Personal Data processed: various types of Data as specified in the privacy policy of the service.

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Place of processing: United Kingdom – Privacy Policy.

Infrastructure monitoring

This type of service allows www.thewellsclinic.com to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.

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Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of www.thewellsclinic.com.

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Sentry (Functional Software, Inc. )

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Sentry is a monitoring service provided by Functional Software, Inc.

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Personal Data processed: various types of Data as specified in the privacy policy of the service.

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Place of processing: United States – Privacy Policy.

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; Usage Data.

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

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.

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.

User database management

This 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; various types of Data as specified in the privacy policy of the service.

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Place of processing: United Kingdom – Privacy Policy.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

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In particular, Users have the right to do the following, to the extent permitted by law:

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• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

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Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Cookie Policy

Www.thewellsclinic.com uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of www.thewellsclinic.com or the related Services.

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The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, www.thewellsclinic.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, www.thewellsclinic.com and any third-party services may collect files that record interaction with www.thewellsclinic.com (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Www.thewellsclinic.com does not support “Do Not Track” requests.

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To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within www.thewellsclinic.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

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Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

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.