Our commitment to your privacy
Information we gather and track
How we use your information
How long your information is kept for?
How your information is protected?
Extent of terms
How to contact us
(effective from 24th May 2018)
“Personal data” is any information about you and which could identify you.
“Special categories of personal data” includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation.
“Processing” means any use of your personal data e.g. collecting, recording, storing, amending, disclosing, retrieving or destroying it.
“Data controller” is the person or body who, alone or with others, is in charge of how and why your personal data is processed.
“Data processor” is the person or body who processes your personal data for the data controller.
“Application” means the hardware or software which collects your personal data, so for us this includes the LighterLife website, members area, game and app.
“User” means you, the person using an application.
We collect and process a range of personal data about prospective customers, existing customers, application users, people seeking a franchise opportunity, and existing franchisees.
We may collect it in several different ways, including when you’re accessing or signing up to our services, activities or online content, or when you’re visiting a LighterLife Counsellor or Mentor.
These are the general categories of personal data we may collect and process about you, depending on the purpose:
- Profile data – for example, your name, gender, height, date of birth.
- Contact data – for example, your email address, postal address, land line or mobile number.
- Health data – for example, from your Wellness Profiles and Wellness Updates.
- LighterLife plan data – for example, weekly weigh-ins, which group activities you’ve taken part in, photographs.
- Account data – for example, orders, baskets, carts, delivery and billing addresses, payments, product reviews, subscriptions.
- Application data – for example, registration, authentication, weights, game points, app achievements, goals, open letters.
- Usage data – this is information collected automatically from applications (or third-party services employed by LighterLife), for example IP addresses or domain names of the computers you use, length of time spent on each page.
- Correspondence data – for example, in the form of email, telephone conversation notes, live chat, surveying, complaints, letters.
- Telephone data – for example, inbound call details, dialled numbers, recordings.
- Competition data – for example, entrants and winners via our website, social media platforms, magazines.
- Activity data – for example, information on steps walked, heartbeat or pulse rate collected by your device. Third parties may be involved in activity tracking e.g. Apple HealthKit (Apple Inc.) is an activity data-handling service provided by Apple Inc. that enables the application to access or store data about movement activity.
- Public relations data – for example, journalist details, client success stories and images.
- Franchise data involved in recruiting and managing LighterLife franchisees – for example, information on the business, background checks, training and bank details.
An application may also provide you, upon request, with additional information about particular services or the collection and processing of your personal data.
Our applications and services are not designed for use by anyone under the age of 16.
We will never knowingly ask anyone under the age of 18 to submit personal information without parental consent.
We use your personal information to maintain and manage your account, deliver the services you’ve requested, and enhance your experience of our services.
This includes providing you with:
- Our services, activities or online content, and giving you information about them.
- Mentoring support on your LighterLife journey.
- The most user-friendly, online navigation experience.
- Personalised services where we analyse the information you supply, as well as your activity on our (and other) services, in order to offer you a more relevant service.
- Information which may be of interest to you (where you consent to receiving this).
It also includes:
- Dealing with your requests and enquiries.
- Processing your orders for products, participation in groups and requests to become a LighterLife franchisee.
- Tracking back your membership and magazine subscriptions, purchases of LighterLife products and services to a LighterLife Counsellor or Mentor or medical practitioner who referred you to LighterLife.
- Applying safeguards to ensure you’re offered the right LighterLife plan.
- Keeping track of your LighterLife journey.
- Locating and putting you in touch with a LighterLife Mentor or Counsellor.
- Managing LighterLife competitions.
- Sending you surveys and other administrative and marketing communications.
- Using prospecting and retargeting services provided by, for example, Google and Facebook.
- Listening to telephone recordings in response to queries, or for training and development purposes.
- Using IP addresses and device identifiers to identify your location, to block disruptive use, to establish the number of visits from different countries, and to determine whether you’re accessing the services from the UK (if not, you may be redirected to the international version of the LighterLife website).
- Using and disclosing information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
We use tracking information to determine which areas of our sites you like and don’t like, based on the overall traffic to those areas. We don’t track what you read, but instead how well each page performs overall. We track search terms entered in search functions as one of many measures of what interests our users, but we don’t track which terms a particular user enters. This all helps us build a better service for you.
Contacting you for marketing purposes
We’ll only send you marketing emails or contact you where you’ve given us your consent for this.
We offer regular emails to let you know about exclusive offers, competitions, tips, weight-loss support and other exciting LighterLife information, ranging from celebrity news to business opportunities.
If these are similar to products, services and competitions previously supplied by us to you, we will assume, under our legitimate interests to promote similar goods and services, that you are willing to receive this information unless you tell us otherwise.
We may personalise the message content based upon any information you’ve given to us and your use of our applications.
You can “opt out” of marketing communications at any time – email us at email@example.com and insert “UNSUBSCRIBE” as the subject, or click on the “UNSUBSCRIBE” link at the bottom of marketing emails.
Sharing your personal information with third parties
We make contracts with other companies to obtain services on our behalf, including order fulfilment, credit-card processing, delivery and marketing. We provide these companies only with the information they need to perform these specific services, and they are permitted to use the information only for those purposes, or as required by law, or if you’ve agreed to any additional use or sharing of your information.
We’ll share your personal information with your local Mentor or Counsellor from time to time to enable them to contact you to:
- Provide you with support and counselling services
- Conduct market research and surveys (if you have chosen to participate)
- Send you information (if you have consented to receive this)
International data transfers
If we transfer any of your personal information outside the EEA (European Economic Area) to an “international recipient” (e.g. where we use an off-shore, Cloud-based provider to store data), we’ll ensure that recipient complies with all applicable data-protection laws.
Any transfer of your data will be subject to adequate levels of protection that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
We, and any companies processing your data on our behalf, only keep information about you for as long as we need to. Our internal retention policy has varying retention periods for different categories of information, depending on our legal obligations and whether there is a commercial need, such as answering customer-account queries. When your personal information is deleted, it’s anonymised for analytical purposes.
We will remove your data from our systems at the end of the applicable data retention periods, unless we are required by current or future law to retain your personal information for a longer period.
We take the security of your personal information seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure data is not accessed without our authorisation.
Where we use third parties to process personal data on our behalf, they:
- Do so under contract and on the basis of our written instructions.
- Have a duty of confidentiality.
- Have to implement appropriate measures to ensure the security of data.
All personally identifiable information is subject to restricted access to prevent unauthorised access, modification or misuse. Please note, however, that we may release your personal data if required to do so by law, search warrant, subpoena or court order.
While we take commercially reasonable measures to ensure the safety and security of your data, due to the inherent risks with the Internet, we are unable to warrant the absolute security of your data when using our services.
As a data subject, you have a number of rights regarding your personal information.
Subject access requests
You have the right to make a subject-access request. If you do so, we’ll tell you:
- Whether or not your data is processed and if so, why, the categories of personal data concerned, and the source of the data if it’s not provided directly by you.
- To whom your data may be disclosed, including any recipients outside the EEA and safeguards apply to such transfers.
- For how long your personal data is stored (or how that period is decided).
- Your rights to have your data corrected or erased, or to restrict or object to its processing.
- Your right to complain to the Information Commissioner if you think we’ve failed to comply with your data-protection rights.
- Whether or not we carry out automated decision-making, and the logic involved in any such decision-making.
We’ll also provide you with a copy of the personal data that is being processed. This will normally be in electronic form if you’ve made a request electronically, unless you agree otherwise. If you want additional copies, we’ll charge a fee based on the administrative cost of doing this.
We normally respond to a request within one month of the date we receive it. In some cases, such as where we process large amounts of your data, we may respond within three months of the date we receive your request; we’ll write to you within one month of receiving your original request if this is the case.
If a subject-access request is manifestly unfounded or excessive (i.e. one which repeats a request we have already responded to), we don’t have to comply with it, but we will let you know that this is the case. Alternatively, we can agree to respond but will charge a fee based on the administrative cost of doing so.
To obtain a copy of the personal data we hold about you, please write to us at:
Privacy Co-ordinator, LighterLife, Cavendish House, Parkway, Harlow Business Park, Harlow, Essex CM19 5QF, enclosing your postal details and proof of identification (a copy of your driving licence or passport, signed and dated by you).
You also have a number of other rights over your personal data. You can request that we correct inaccurate data and that we stop processing any data that is inaccurate or if there is a dispute about whether or not your interests override LighterLife’s legitimate grounds for processing it.
You can also request that we stop processing, or erase, any data:
- That is no longer necessary.
- If your interests override our legitimate grounds for holding or processing it (where we rely on our legitimate interests as a reason for holding or processing data).
- If processing it is unlawful.
Send your request to firstname.lastname@example.org. In some cases, we may need to ask for proof of identification before we can process it. We’ll let you know if we need to verify your identity and the documents required for doing so.
Many features available through our applications don’t require you to register your personal information with us. However, if you’re interested in obtaining information, products or services from us or in participating in certain activities through our applications, you may need to give us some personal information – for example, to enable us to process an online shop order that you’re placing.
You are responsible for any personal data of third parties that you obtain, publish or share through an application and you must confirm that you have the third party’s consent to provide this data.
We also collect non-personal data through aggregated tracking information, mainly by tallying page views throughout our websites; this allows us to better tailor our content, products and services to the needs of all our customers, including you.
Apps and devices
When you download or use any of our apps on your mobile device, information may be accessed from or stored on it. Most often this is used in a similar way to a web browser cookie – for example, to enable the app to “remember” you or provide you with the content you’ve requested.
Your web browser or device may also provide us with information about it, such as a device identifier or IP address, and this data may be collected automatically.
When you sign in to one of our apps, your sign-in details may be stored securely on the device you’re using, which means you can access other LighterLife apps on the same device without needing to sign in again.
Registration and authentication
By registering or authenticating your personal information with us, you allow our applications to identify you and give you access to dedicated services.
Third parties may provide registration and authentication services. When this is the case, the application may be able to access some data, stored by these third-party services, for registration or identification purposes.
Our applications may ask for some Facebook permissions allowing them to perform actions with your Facebook account and to retrieve information, including your personal data, from it. This includes:
- Using Facebook Authentication (Facebook, Inc.) – a registration and authentication service provided by Facebook which is connected to the Facebook social network.
- Access to “Basic information” – by default, this includes some of your personal information, including ID, name, picture, gender and where you live. Some of your connections, such as Friends, are also available. The more of your Facebook data you’ve made public, the more information will be available to our applications.
- Access to “About me” – provides access to the “About Me” section of your profile.
- Access to “Contact email” – provides access to your contact email address.
- Access to the Facebook account: this allows our applications to connect with your account on the Facebook social network.
- Facebook Like button and social widgets (Facebook, Inc.) – these are services allowing interaction with the Facebook social network.
Access to third party services’ accounts
This allows our applications to access and use data from your account on a third-party service, but only with your explicit authorisation.
Linking to other websites
Our applications may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies about the use of personal information you submit while visiting them, so it’s a good idea to review them. We don’t accept any responsibility or liability for the privacy practices of such third-party websites.
Interaction with external social networks and platforms
This allows interaction with social networks or other external platforms directly from our applications, subject to your privacy settings for each social network. However, this type of service might still collect traffic data for pages where the service is installed, even when you don’t use it.
System logs and maintenance
For operation and maintenance purposes, an application and any third-party services may collect files that record interaction with an application (system logs) or use for this purpose other personal data (such as an IP address).
We track user traffic patterns throughout all our sites. While we don’t link this to data about individual users, we do break down overall usage statistics according to a user’s domain name, browser type and MIME type (i.e. identifying files on the internet according to their nature and format).
Different kinds of cookies do different things, ranging from making a website work to making it easier to use and enabling website owners to understand more about their visitors.
- Ensure your privacy is safeguarded in any secure area.
- Gather information about which pages are most relevant to our visitors.
- Store details you enter into our calculators, tools and demos so you can make the most of our online services.
- Store details of your marketing, product and other preferences to enhance your visits.
- Evaluate how effective our advertising and promotions have been to improve our performance.
- Store information which enables you to be personally identified.
- Track your browsing after you’ve left our websites.
- Sell or distribute cookie data (without your consent).
Up-to-date browsers give you the option to accept or decline cookies. This applies to every website you visit.
If you switch off cookies at the browser level, your device won’t be able to accept cookies from any website, which means you’ll struggle to access the secure area of any website you use and you won’t enjoy the best browsing experience when you’re online.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Your personal data may be used for legal purposes by LighterLife, in court or in the stages leading to possible legal action arising from improper use of this application or the related services.
You (the user) declare to be aware that LighterLife (the data controller) may be required to reveal personal data if requested to by public authorities.
The services on this website and use of LighterLife applications are only for residents of the United Kingdom and the Republic of Ireland. Information regarding products, services, rates and promotions are applicable to these countries only. The materials contained in the site and applications are inappropriate for, not available in and irrelevant to, any other location.
Parkway, Harlow Business Park,
Harlow, Essex CM19 5QF