"The Flourish Initiative” is a UK registered company.
As a company processing your personal data, we are regulated by the General Data Protection Regulation (GDPR). This page is intended to keep you informed about what we do with the personal data we process. ‘Personal data’, for the purposes of the GDPR, means any information from which you can be identified; it includes things like your name, date of birth, e-mail address, delivery address, billing address, telephone number and IP address.
First of all, we’d like to assure you that we are committed to protecting the privacy of all our users. We will endeavour to ensure that the information you provide us with is kept secure and managed within the General Data Protection Regulations.
If you are not happy with any aspect of how we collect and use your data, please let us know so we can try and resolve it for you. Should this not be resolved, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
It is important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes by emailing us at firstname.lastname@example.org.
What information we will collect about you
We collect information about you when you register with us or place an order for products or services. We also collect information when you complete surveys, provide feedback or supply us with information during the course of our relationship. Website usage information is collected using cookies.
We may process certain types of personal data about you as follows:
Identity Data may include your first name, last name, username, title, date of birth and gender.
Contact Data may include your billing address, delivery address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us and other details of purchases made by you.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We may request to collect sensitive data about you in order to provide our therapy services and/or carry out surveys. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and information about your health. Depending on the purpose, we may require your explicit consent for processing sensitive data, if so we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you, if you do not provide us with that data when requested, we may not be able to perform the contract (for example, to provide services to you). If you don’t provide us with the requested data, we may have to cancel a service you have requested but if we do, we will notify you at the time.
2. How We Collect Your Personal Information
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
order our products or services;
create an account on our site;
subscribe to our service or publications;
request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or
give us feedback.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google based outside the EU;
advertising networks such as Facebook based outside the EU; and
search information providers such as Google and BING based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay and PayPal, based inside and outside the EU, and Shopify based outside the EU
Identity and Contact Data from data brokers or aggregators, for our business-to-business customers only.
3. How We Use Your Personal Information
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Purposes for Processing Your Personal Information
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To open an online account||(a) Identity
(d) Marketing and Communications
|Performance of a contract with you|
|To process and, where required, deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests to recover debts owed to us
|To run classes, talks, events or 1:1 sessions which you have purchased or registered for. This may include sharing your data with third parties who are hosting or delivering the service.||(a) Identity
|Necessary for our legitimate interests as a business to be able to contact you regarding this service and track attendance.|
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
| (a) Identity
(d) Marketing and Communications
| (a) Performance of a contract with you |
Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
|To enable you to partake in a prize draw or competition||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you|
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise|
(b) Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising|| (a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|| (a) Technical
|Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|| (a) Identity
|Necessary for our legitimate interests to develop our products/services and grow our business|
|Use of our App||(a) Identity
(c) Profile Data
(d) Technical Data
| (a) Performance of a contract with you - acceptance of the T&Cs form part of the App download so we can provide this service to you, |
(b) Necessary for our legitimate interests to be able to provide the App service to you. Full details can be viewed via the 'Terms and Privacy' section within the App
You will receive marketing communications from us if you have:
(i) requested information from us or purchased goods or services from us; or
(ii) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
(iii) in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at email@example.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
4. Disclosures of Your Personal Information
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
Third parties who provide fulfillment, marketing and customer support services, such as warehouses and logistics companies, review platforms, email marketing services, marketing automation platforms, social media platforms and Google Ad services (for example, for display advertising and retargeting), and membership service providers.
Therapists and course leaders.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We will not share your details with any other third parties unless we have your explicit consent.
However, if we reasonably believe that we are required by law to disclose your personal information to a third party, whether in compliance with any applicable law or regulation or by court order or in connection with legal proceedings, we may do so. We may also use aggregate anonymised data and share it with third parties.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
If we collect information about you from outside the European Union we may transfer that data into a country which is a Member State of the European Union.
Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
However, please note that purchasing a ticket for an event outside the European Union, or purchasing goods to be sent to an address outside of the European Union, may require us to transfer your data to third parties outside the European Union, for example to the event venue, for the purpose of fulfilling our obligations under the contract, and you consent to this where purchasing goods or services in the above circumstances.
5. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
6. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
However, we cannot absolutely guarantee the security of your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
You can choose not to accept cookies and the above websites tell you how to remove cookies from your browser. However this may prevent our website from functioning properly.
9. Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We reserve the right to change this policy at any time. However, we will not change the way we use your personal information without telling you in advance and giving you the chance to opt out of or prevent the new use of your information.
Last updated: May 2019