Privacy Policy

Privacy policy

INTRODUCTION

QC Wellbeing CIC (“QCW”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. Please read this Privacy Policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

DATA CONTROLLER

A data controller is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise, we are the data controller of your personal data for the purpose of this website and where we directly interact with you.

If you have any questions about this policy or about how we handle your data, please contact us by telephone at 07909502808 or by email at info@querenciaconsultants.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

COLLECTION OF YOUR PERSONAL DATA

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of data protection laws.

We collect personal data from you when you order goods or services from us, use our website, or use third party websites linked to our website.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together. The type of personal data we process about you will be dependent on your relationship with us:

Identity Data: includes your first name, last name, pronouns, username, location name or similar identifier and title.
Contact Data: includes your billing address, email address, telephone number and any social media identifiers.
Financial Data: includes your bank account and payment card details.
Marketing Data: includes your preferences in receiving marketing communications from us or third parties.
Profile Data: includes your username and password, feedback, and your responses to surveys, competitions and promotions, your contact history, purchase history and saved items.
Usage Data: information about how you use our website, IT, communication and other systems.
Technical Data: includes your computer’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, the device type, operating system, unique device identifiers, device settings, and geo-location data.
Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.

PERSONAL DATA FROM PERSONS UNDER THE AGE OF 18

Any personal information related to children (under age 18) will not be knowingly collected without the consent of their parent or guardian.

QCW does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

apply for a membership with QCW;
create an account on our website;
subscribe to our publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties. We may receive personal data about you from various third parties such as:

analytics providers such as Google;
providers of technical, payment and delivery services.

HOW WE USE PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
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. As you are engaging in a fitness activity, we will ask consent to process any sensitive information on medical conditions. Provision by you of such information is voluntary, however if it is evident to us that the type of exercise we offer may not currently be suitable for you, we retain the right to withhold our services from you.
Where we need to comply with a legal obligation.
In limited circumstances where you have given your consent.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

For the provision of our services to you

(a) Identity

(b) Contact

Performance of a contract with you

To respond to any enquires

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

Screen our orders for potential risk or fraud

(a) Identity

(b) Contact

Legal obligation

To process and deliver our services to you including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests i.e., to recover debts due to us

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests i.e., to keep our records updated and to study how customers use our products/services

To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

(a) Identity

(b) Contact

(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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests i.e., 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

(b) Usage

Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice

To make suggestions and recommendations to you about our services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests to develop our products/services and grow our business

MARKETING COMMUNICATIONS

We may send you marketing communications. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us using the details provided above.

Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our services, your service experience or other interactions with this website.

SHARING YOUR PERSONAL DATA

We do not and will not sell any of your personal data to any third party, including your name, contact information or payment information. We may have to share your personal data with the parties set out below:

Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.
Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.
Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
Advertising networks and analytics service providers: This is to support and display ads on our website and other social media tools.

Third parties: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy notice.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK or the European Economic Area.

DATA SECURITY

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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

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.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws. Not all rights are absolute and will depend on certain circumstances. You can:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

CARRYING OUT YOUR DATA SUBJECT RIGHTS

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. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information 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. If you wish to exercise any of the rights set out above, please contact us at contact@auroboros.co.uk

CHANGES

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable data protection laws.

CONCERNS AND COMPLAINTS

We would appreciate the chance to deal with your concerns in the first instance. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

Policy last updated: [ ] 2025