Privacy Policy

This Privacy Policy informs you about the personal data that is collected, why we

collect it and how we process it when you visit our website or use our smart phone

and tablet application (collectively “application”).

Our commitment to data protection

The Well-Being Collective takes the protection of your personal data seriously. We

treat your personal data confidentially.

Trust is one of the foundations of the The Well-Being Collective application and

includes trusting us to do the right thing with your information. Three main values

guide us as we develop our products and services. These values should help you

better understand how we treat your information and privacy.

● Your information belongs to you. We carefully analyse what types of

information we need to provide our services, and we try to limit the

information we collect to only what we really need. Where possible, we

delete or anonymise this information when we no longer need it. When

building and improving our products, our engineers work closely with our

privacy and security teams to build with privacy in mind. In all of this work,

our guiding principle is that your information belongs to you, and we aim to

only use your information to your benefit.

● We protect your information from others. If a third party requests your

personal information, we will refuse to share any information which is not

required. When we are legally required to share your personal information,

we will tell you in advance, unless we are legally forbidden.

● We help suppliers and partners meet their privacy obligations. Many of the

suppliers and partners using The Well-Being Collective do not have the

benefit of a dedicated privacy team, and it is important to us to help them

meet their privacy obligations. To do this, we try to build our products and

services so they can easily be used in a privacy-friendly way.

The following company is responsible for data processing on our website:

The Well-Being Collective,

Ikigai Riverside, Merchant Square,Riverside Drive, Nairobi

www.wellbeingcollective.net

hello@wellbeingcollective.net

1. What personal data do we collect?

We collect and process personal data in the following situations: When you visit

our website, use our contact form or the application, purchase a subscription or

other services from us. Further data, which is recorded in server log files when you

visit our website and which your internet browser automatically transmits to us, is

recorded on an anonymous basis. This data includes the user agent (browser type

and version, operating system used), http header information (referrer URL, IP

address of the accessing computer), the time of the server request and the login

status. These server log files are merged with other data sources for error analysis

only.

2. How and when do we collect your personal data?

We collect personal data that you communicate to us directly. This is personal data

that you enter in a contact form or general personal data that you provide in the

course of a registration process on our application and the photo that you upload

when you register. If you purchase a subscription, use the application or use other

services from us, additional personal data may be collected and processed, i.e.

customer data (initial date of subscription, customer account, etc.) and information

on the use of our services.

We might also receive personal information from third parties. This specifically

involves data related to your use of the facilities of our sports partners (e.g. access

times to sports facilities, etc.). This data will be treated with the same care and level

of security as any other personal data.

Further data is automatically collected by our IT systems on an anonymous basis

when you visit our website. This data is mainly of a technical nature (e.g. Internet

browser, operating system or time of page request) as well as data on the pages,

products and services on our website that you view. This data is collected

automatically as soon as you access our website. The data collected also includes

personal data with which you can be personally identified, such as your IP address.

3. For what purpose do we collect and process your personal data?We collect and process your personal data in order to carry out and process our

contractual relationship with you and to enforce our claims.

Within the framework of our contractual relationship, we collect and process this

personal data principally for the analysis of your user behaviour. Such analyses

serve to settle accounts with our sports partners and to optimise the application,

which includes the automatic display of offers that may be of interest to you. We

collect, process and use the personal data that is collected when you use the

application (e.g. data on use, such as sports facilities, frequency of visits, type of

sport) only if you agreed to data processing in the course of the registration process

on our application. Among other things, data processing helps us to better tailor the

contents of our application to your needs and preferences, improve product search

functions for you or display advertisements or offers that might be of interest to

you. The personal data collected will be deleted if you revoke your consent;

statutory retention periods remain reserved.

If you have registered with us, we will also process your personal data for

marketing purposes, for example to send you emails with general information or

with references to certain offers and events. You can unsubscribe from these emails

at any time.

We use your personal data to ensure the correct performance of the contract. This

includes processing to detect false or misleading information and to prevent the use

of our services in breach of the law or the contract. For this purpose, we also collect

data on the use of our services with the help of cookies. We process this

information in order to check for evidence of abuse.

If you have not registered on our application, we collect, process and use data about

the use of our website only in anonymous form. In this case, the functions named

above will be severely restricted, i.e. the possible adaptations of our website, the

search functions or the advertisements and offers displayed will not be tailored to

your needs and interests to the same extent.

Some personal data is collected to ensure an error-free provision of our application.

Registration on our ApplicationYou can register on our application to use additional functions. The mandatory

information requested during registration must be provided in full, otherwise we

will refuse registration. We use the personal data collected to provide the offers or

services for which you have registered. In addition, we use your email address to

inform you of important changes, such as to the scope of the offer, or of technical

modifications that are necessary.

The personal data collected during registration is stored for as long as you are

registered on our application. It will then be deleted; statutory retention periods

remain reserved.

Use of the Contact Form

If you send us inquiries via the contact form, your details on the inquiry form

including the contact data you provided in that form will be stored by us for the

purpose of processing the inquiry and for any follow-up questions. We do not pass

on this personal data without your consent.

The personal data you enter in the contact form will remain with us until you

request us to delete it or until the purpose for which the data was stored no longer

applies (e.g. after your request has been processed). Statutory retention periods

remain reserved.

4. On what legal basis do we collect and process your personal data?

The legal basis for the collection and processing of your personal data is above all

the contractual relationship you enter into with us when you use our services. Upon

entering into a contract with us you give your consent to this Privacy Policy.

Your consent at the time of collecting your personal data also serves as a basis. You

may revoke your consent at any time. It suffices if you send us an informal

notification by email for this purpose. The legality of the data processing that has

already taken place remains unaffected by the revocation.

In addition, we collect and process your personal data to protect our legitimate

interests, such as to operate our application properly, update the technologies used,

improve our services and enforce our claims, etc. In this context, we naturally ensure

that your interests are not unduly adversely affected.5. To whom do we pass on your personal data?

Within the framework of your subscription we may pass on your personal data to

The Well-Being Collective suppliers. They may also process and use your personal

data in their own interests for the purposes stated in this Privacy Policy.

We may also disclose your personal data to our external contractual partners if this

is necessary for the performance of the contract (e.g. to pay admission fees) or if

they process the personal data on our behalf, for example because we use their

services. Such external contractual partners are contractually obliged to process

your personal data exclusively on our behalf and in accordance with our

instructions. These contractual partners also undertake to ensure the security of

your personal data by taking suitable technical and organisational measures.

If our external contractual partners are located abroad, your personal data might be

transferred to other countries. However, this presupposes that data protection in the

country concerned is comparable with Kenyan law or that appropriate precautions

have been taken.

We may disclose your personal data when necessary to comply with applicable

laws, in connection with legal proceedings, at the request of government

authorities, to comply with our legal obligations or to enforce and protect our rights.

6. How long do we store your personal data?

We store your personal data for as long as necessary or useful for the purposes for

which it was collected, but for no longer than we are permitted to do so by law. We

delete your personal data as soon as it is no longer required, however, at the latest

after the expiry of the statutory retention period.

7. How do we protect your personal data?

We have taken suitable technical and organisational measures to prevent

unauthorised or unlawful access to your personal data. It is important that you are

aware that the transmission of data via the internet or other electronic media poses

certain security risks and that complete data security cannot be guaranteed even

when communicating by email. We cannot therefore guarantee the security of data

transmitted to us through these media.For security reasons and to protect the transmission of confidential information (e.g.

registration), our website uses SSL or TLS encryption. You can recognise an

encrypted connection by the fact that the address line of the browser changes from

http://” to “https://”

, and by the lock symbol in your browser line. Payment

transactions via the usual means of payment (e.g. Visa/MasterCard, etc.) are carried

out exclusively via an encrypted SSL or TLS connection.

8. What rights do you have?

Revocation of your consent to data processing

Certain data processing operations are permitted only with your consent. You may

at any time revoke any consent you have already given. It suffices if you send an

informal notification to us by email for this purpose. The data processed until

revocation remains unaffected by the revocation.

Information, blocking, deletion

Within the scope of applicable legal provisions, you have the right at any time to

obtain information free of charge on the personal data stored on you, its origin and

recipients, the purpose of data processing and, if applicable, a right to correction,

blocking or deletion of your personal data. Please feel free to contact us at any time

at the address given at the outset if you have any questions about this or about data

protection.

Complaint to the supervisory authority

In the event of a breach of data protection, you have the right to appeal to the

Kenyan Data Protection Commissioner.

Updating this Privacy Policy

We may update, supplement or amend this Privacy Policy at any time without

notice.9. How do we use cookies?

Cookies are used on our website. These are small text files that are placed on your

computer and stored by your browser. Cookies serve to make our services more

user-friendly, effective and secure and do not cause any damage to your device.

Most of the cookies we use are referred to as “session cookies”

. They are

automatically deleted at the end of your visit to our website. Other cookies remain

stored on your device unless you delete them. These cookies enable us to recognise

your browser the next time you visit us.

You can set your browser so that you are informed whenever cookies are placed on

your computer and only allow cookies on a case-by-case basis, accept cookies in

certain cases or generally reject them and activate the automatic deletion of cookies

when the browser is closed. However, if cookies are deactivated, the functions of

our website might be restricted.

10. How do we use social media plugins?

Social media plugins are recommendation buttons for the social networks of

Facebook, X, Instagram and Google+. These are provided by the operators of these

social networks. By placing the plugins on our website, these social network

operators can obtain information about your visit to our website. If you are logged

into one of these social networks when you visit our website, the social network

operator can assign this visit to your user account. If you do not wish this to occur,

you should log out of the social networks before visiting our website. If you click on

these recommendation buttons, this information will be forwarded to the social

network concerned and stored there. Information about the collection and

processing of data by social networks and how you protect your privacy can be

found on the relevant social network websites:

Facebook: https://facebook.com/policy.php

X: https://x.com/en/privacy

Youtube: https: //www.google.com/policies/privacy

Instagram: https: //instagram.com/about/legal/privacy/

LinkedIn: https: //www.linkedin.com/legal/privacy-policy11. How do we use website analysis services?

Google Analytics

Our website uses functions of the Google Analytics web analysis service. The

provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043,

USA

Google Analytics uses “cookies”

. These are text files that are stored on your

computer and allow an analysis of the use of our website. Google evaluates the use

of our website to compile reports on website activities and to provide The

Well-Being Collective with other services relating to website use and use of the

Internet. Our primary purpose is to optimise our website to provide you with an

enhanced online experience on our website. The IP address transmitted by your

browser within the framework of Google Analytics is not combined with other data

of Google.

The information generated by the cookie about your use of our website will usually

be transmitted to and stored by a Google server in the USA. Google complies with

the data protection provisions agreement and has registered with the U.S.

Department of Commerce.

Our website has activated the IP anonymisation function. This will cause your IP

address to be shortened by Google before it is transmitted to the USA. Only in

exceptional cases will the full IP address be transmitted to a Google server in the

USA and shortened there.

You may refuse the storage of cookies by entering an appropriate setting in your

browser software, however we wish to point out that by doing so you may not be

able to use all the functions of this website. You can also prevent Google from

collecting and processing your personal data by downloading and installing the

browser plugin available from the following link:

https://tools.google.com/dlpage/gaoptout?hl.

In this case, an opt-out cookie will be set to prevent the collection of your personal

data when you visit this website in future.

Our website uses the “demographic functions” function of Google Analytics. This

allows reports to be created that contain information on the age, gender andinterests of website visitors. This data is generated from interest-related Google

advertising and from third-party visitor data. This data cannot be assigned to a

specific person. You can deactivate this function at any time using the advertisement

preferences in your Google account or generally prohibit the collection of your data

by Google Analytics.

For more information, please see Google's privacy policy at

https://support.google.com/analytics/answer/6004245?hl.

Google Analytics Remarketing

Our website uses Google Analytics Remarketing functions in connection with the

cross-device functions of Google AdWords and Google DoubleClick. The provider is

Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This function allows you to link the advertising target groups created with Google

Analytics Remarketing with the cross-device functions of Google AdWords and

Google DoubleClick. This enables interest-related, personalised advertising

messages that have been tailored to you personally based on your previous usage

and surfing behaviour on one terminal (e.g. mobile phone) to be displayed on

another of your terminals (e.g. tablet or PC).

Provided you have given Google your consent to do so, Google will link your web

and app browser history to your Google account for this purpose. In this way, the

same personalised advertising messages can be displayed on any terminal device

you sign in to with your Google account.

To support this function, Google Analytics collects Google-authenticated user IDs

that are temporarily linked to our Google Analytics data to define and create target

groups for cross-device advertising.

You can permanently opt out of cross-device remarketing by deactivating

personalised advertising in your Google account at

https://www.google.com/settings/ads/onweb/ .

For more information, please see Google's privacy policy at

https://www.google.com/policies/technologies/ads/ .

Google AdWords and Google Conversion TrackingOur website uses the online advertising program Google AdWords. The provider is

Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

We use what is known as conversion tracking within the framework of Google

AdWords. When you click on an advertisement placed by Google, a conversion

tracking cookie is set. Cookies are small text files that the Internet browser stores

on your computer. These cookies lose their validity after 30 days at the latest and

do not serve to identify you. If you visit our website and the cookie has not yet

expired, Google and we can see that you clicked on the advertisement and were

directed to that page.

Google informs us of the total number of users who clicked on our advertisement

and were directed to our website with a conversion tracking tag. However, we do

not receive any information that will allow us to personally identify them.

You may prevent the storage of cookies by entering an appropriate setting in your

browser software, however we wish to point out that by doing so, you may not be

able to use all the functions of this website. You can also prevent tracking by

deactivating the Google Conversion Tracking cookie in your Internet browser under

user preferences.

For more information, please see Google's privacy policy at

https://www.google.com/policies/privacy/ .

Visitor action pixel

Our website uses the visitor action pixel of Facebook. The provider is Facebook Inc.,

1601 S. California Ave, Palo Alto, CA 94304, USA.

The Facebook pixel can be used to track the behaviour of website visitors after they

have been redirected to our website by clicking on a Facebook advertisement. This

allows the effectiveness of Facebook advertisements to be evaluated for statistical

and market research purposes and future advertising measures to be optimised.

The collected data is anonymous for The Well-Being Collective, we cannot draw

any conclusions about your identity. However, the data is stored and processed by

Facebook so that it can be linked to the respective user profile and Facebook can

use the data for its own advertising purposes in accordance with the Facebook DataUsage Guidelines. This enables Facebook to place advertisements on Facebook

pages and outside Facebook. The Well-Being Collective cannot influence this use of

the data.

You can permanently object to remarketing by deactivating the remarketing function

“Custom Audiences” in the settings for advertisements under

https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You

must be logged in to Facebook for this purpose.

For further information, please see Facebook's privacy policy at

https://www.facebook.com/about/privacy/ .

12. Which payment services and payment methods are available?

All common means of payment can be processed via the interface of the payment

provider Paystack. The provider is Paystack, The Pavilion (1st Floor), Lower Kabete

Road, Westlands, Nairobi, Kenya. The payment data you enter is transmitted

directly to Paystack. Credit card data is neither collected nor processed by us. We

then send the information about your chargeable use to Paystack, i.e. name,

member number, email, invoice amount, currency. The transfer of your data to

Paystack is solely for the purpose of payment processing with the payment service

provider. The terms of use of Paystack can be found at

https://paystack.com/ke/terms?q=/terms.