1. Your Information
• How we collect or obtain information about you: When you contact us via email or telephone, place an order with us, complete registration or contact forms, sign up for free trials, consultations, memberships, submit and complete surveys, share pertinent health and wellness data, or sign up for content such as newsletters, and occasionally data collected from third parties such as mailing list providers, we collect information that you voluntarily provide us about you and informaiton that is gathered to fulfill our contractual obligations.
• Information we collect: By and large we collect email addresses, phone numbers, first name, last name, demographic information such as age, date of birth, gender, and any wellness issues and goals you may have and any data fromwellness surveys that you voluntarily choose to participate in. You may also voluntarily choose to share additional data with us to help us serve your health and wellness needs better.
• How we use your information: To fulfill our contractual obligations to you, for administrative and business purposes (particularly to contact you and process orders you place on our website or directly with us), to respond to queries, posts and responses to surveys, to improve our business, to advertise other goods and services, to market directly to you, also and in connection with our legal rights and obligations.
• Disclosure of your information to third parties: User information may be shared with our partners only to the extent necessary to fulfill our contractual obligations to you, to run our business efficiently, with specific employees or affiliates, and where required by law or to enforce our legal rights. However, we do not share your information with any other organisations involved in your care without specific consent from you and as detailed in our contracts. We do not disclose your information to any other third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing guideline. Our policy is to ensure all personal data related to our customers is fully protected. All employees and subcontractors engaged with us are asked to sign a confidentiality agreement.
• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No, we do not sell or share your data to anyone.

2. How long we retain your information
We take into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described below:
• Server log information: We retain information on our server logs for 6 months.
• Order information: When you place an order for goods and services, we retain that information for seven years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
• Correspondence and enquiries: When you make an enquiry or correspond with us for any reason, whether by email or our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 36 further month(s), after which point we archive your information.
• Digital marketing: We retain the information you used to sign up for our newsletters, etc for as long as you remain subscribed (i.e. you do not unsubscribe).
• Registration: We retain the information you used to register for as long as you remain subscribed (i.e. you do not unsubscribe).

3. How we secure your information
We use appropriate technical and organisational measures such as storing your information on secure servers in India, the US or other countries.
We take personal data seriously and as such we ensure appropriate safeguards are in place. We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

4. Your rights in relation to your information
• to access your information and to receive information about its use
• to have your information corrected and/or completed
• to have your information deleted
• to restrict the use of your information
• to receive your information in a portable format
• to object to the use of your information
• to withdraw your consent to the use of your information
• to complain to a supervisory authority

5. Profiling and sensitive personal information
We do perform various assessments and case studies with your written consent and where applicable to help you meet your goals, to understand our users better, to conduct R&D, and to deliver a personalized user experience. All the data gathered and participation in any of our surveys, case studies and research projects is volunatry, and conducted with specific consent from you.

We do not collect what is commonly referred to as ‘sensitive personal information’, however we will only capture essential minimum data where it is strictly necessary and as stated above.

“Sensitive personal information” is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. Our website may allow you to register sensitive information, however when we ask for this, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation.

6. When you contact us

We collect and use information from individuals who contact us and as per the information you provide us.
• Email
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
• Enquiry forms
When you contact us using an enquiry form, we collect your personal details and match this to any information we hold about you on record. Typical personal information collected will include your name and contact details. We will also record the time, date and the specific form you completed. If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence. We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled “Marketing communications”. Messages you send to us via our contact form may be stored outside the European Economic Area on our contact form provider’s servers.
• Phone
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us. We may record customer-facing phone calls for training and customer service purposes.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
To perform a contract: Where your contact with us relates to us providing you with goods or services or taking steps to do so at your request, and prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.
• Registered Users
When you register as a user on our website:
We collect and store one or more of the following: your email address, first name, last name, phone number, We use this data to provide you with customer support and other services, bill you for our services, collect feedback, send you account-related notifications, and keep you informed about our key features, important feature updates, and latest releases.
We store data related to your surveys, polls, and newsletters in your account that you access using your login ID and password. This includes questions, responses, images, email lists, data you enter while configuring or customizing any settings, etc. This data is processed by SurveyMethods to enable you to perform functions like design and distribution of surveys, polls, newsletters, and analysis & reporting.
We do not share any personally identifiable and account-related data with a third party without your explicit consent.
Your data will be visible to those with whom you share your published reports or extracted data/reports.
To prevent any undesirable, abusive, or illegal activities, we have automated processes in place that check your data for malicious activities, spam, and fraud.
We may use your data if required by law, court orders, subpoenas, or to enforce our agreements.
Currently, we do not collect information using cookies. Cookies are digital files that allow websites to recognize returning users.

7. Information received from third parties
We may often receive information about you from third parties. The third parties from which we receive information about you can include partner events within the marketing industry and other organisations that we have a professional affiliation with. It is also possible that third parties with whom we have had no prior contact may provide us with information about you through a database we purchase in accordance with the law.
Information we obtain from third parties will generally be your name and contact details but may also include any additional information about you which they provide to us.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: Where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: Consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: Where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: Where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a subcontract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

8. Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. Examples include: Internet services, IT service providers and web developers.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website, ordering goods and services from us, participating in surveys that are not anonymous, etc.
We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: Where we share your information with these third parties in a context other than where it is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: Necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: We may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

9. Enforcement or potential enforcement of legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Enforcing our legal rights and taking steps to enforce our legal rights.
• In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Resolving disputes and potential disputes.

10. Identity verification
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
• How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

11. Your right to object
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to the data controller using the details provided at the top of this policy.
• to object to us using or processing your information where we use or process it in order
• to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing)
• You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
• Clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link
• Sending an email to info@instituteiwe.org, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

12. Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
• Minor changes to our Privacy Policy Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
• Major changes to our Privacy Policy or the purposes for which we process your informationWhen we make major changes to our Privacy Policy we will post a notice on our website. Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.