Privacy Policy

This Privacy Policy applies to Health Wellness Travel and Leisure Inc. and its wholly owned US subsidiary Vacation Your Way (“Health Wellness Travel and Leisure”, “we”, “us” or “our”), and to any member of our program (“you” or “your”). In this Privacy Policy, Personal Data means any information that identifies or could identify a living individual. This Policy sets forth the standards under which Health Wellness Travel and Leisure Inc. will treat Personal Data. By using Health Wellness Travel and Leisure Inc. services, you are consenting to the practices described in this Privacy Notice.

Data Controller

Health Wellness Travel and Leisure Inc. will be the data controller of your Personal Data that is processed by us. Health Wellness Travel and Leisure Inc. is a company incorporated in the State of Florida. Health Wellness Travel and Leisure Inc. See the Contact Us section at the end of this Privacy Policy for information on how to contact Health Wellness Travel and Leisure Inc..

Your Privacy and the Health Wellness Travel and Leisure membership

Health Wellness Travel and Leisure Inc. is committed to protecting your privacy. This Privacy Policy sets out what data we collect, how we use that data and the choices we offer you, including how to access and update your information.

When you sign up for membership, we provide you with a program that aggregates the purchasing power of millions of individuals in order to create special pricing on a wide range of goods and services (“Program”). As a registered user of the Program, you will immediately benefit from the following features:

As a registered user, you have control over which features of the Program you wish to use. In order that you can receive the full benefit of the program, you will be automatically enrolled at the point of any purchase made through site. If you decide that you no longer wish to participate in the program, you can do so at any time through the “My Account” section of the website or by contacting us at the Contact Us page. We ensure that your Personal Data is processed in accordance with relevant laws and industry-recognized data protection standards. At no time will we trade, sell, or distribute your Personal Data to any individual, company, vendor or organization, in ways other than as disclosed in this Privacy Policy. If you have any questions or concerns regarding our Privacy Policy, please contact us through one of the methods described in the last section of this Privacy Policy.

We may send marketing communications to your individual email address where you have consented to us doing so.

Where we process your Personal Data based on your consent, you have the right to withdraw your consent at any time on the Your Account section or by using the Contact Us page. Any withdrawal of consent by you shall not affect the lawfulness of processing based on your consent before it was withdrawn.

Information We Share

Information about you is an important part of our business. We do not sell your information to any third parties. All information disclosing is based on the principle of sharing only the information necessary to fulfil the legitimate business purpose. When shared, data may be transferred and hosted outside the country of origin. We only share your Personal Data with third parties as set out below:

• Aggregated information showing the general use of the Program without any personally identifying information is shared with your organization to evaluate the effectiveness and value of the Program;
• Information on whether and when you have registered and used the Program may be provided to your organization to minimize redundant or irrelevant communications;
• Information on spending and savings on the Program may be provided to your organization to be included in with other benefits you receive from your organization;
• RSVPs for private, in store events may be provided to participating vendors for admittance to the event;
• Payment card information will be shared with payment card data matching providers including Sports Loyalty Card Limited trading as Reward, Fidel Limited and payment service providers such as Visa, MasterCard and Amex to facilitate card transactions and identify transactions where you have earned or spent;
• Bank account information may be shared with our bank to facilitate payment into your account;
• Information may be shared with participating merchants in order to fulfil your purchase transaction, including payment information, shipping address and other personal information that may be required to complete such transaction;
• If your organization has contracted a third party to run the Program (such as a flexible benefits provider) any of the above information that we share with your organization may also be shared with the third party;
• All of the information we collect, as described above, may be shared with the companies that perform IT services on our behalf such as credit card processors, data management firms, data analytics firms, fraud prevention services and call center providers for the purposes of providing you with the Program and developing and maintaining it. These companies are authorized to use your Personal Data only as necessary to provide these services to us;
• We reserve the right to disclose your Personal Data , to your organization or authorities, as required by law and when it is believed that disclosure is necessary to protect our rights, our clients’ interests and/or to comply with a judicial proceeding, court order, or legal process;
• We will otherwise share your Personal Data with your consent; and
• We reserve the right to share all audio and video data that is generated from any Community Online Academy session that is accessed via your account.

Accountability for Onward Transfer

In the event Health Wellness Travel and Leisure Inc. discloses Personal Data covered by this Policy to a non-agent third party, it will do so consistent with any notice provided to Data Subjects and any choice they have exercised regarding such disclosure. If Health Wellness Travel and Leisure Inc. has knowledge that a third party to which it has disclosed Personal Data covered by this Policy is processing such Personal Data in a way that is contrary to this Policy and/or the applicable data protection principles enshrined in law, Health Wellness Travel and Leisure Inc. will take reasonable steps to prevent or stop such processing. In such case, the third-party is liable for damages unless it is proven that Health Wellness Travel and Leisure Inc. is responsible for the event giving rise to the violation.

Profiling

We use profiling in order to enhance your user experience and to present you with advertising that is relevant to you and in line with your browsing history and past purchases. We do not carry out any automated decision making.

If you exercise your right to object to profiling, then we will unsubscribe you from membership and stop processing your Personal Data in accordance with our retention policy. This is because the type of profiling that we carry out is fundamental to the Program and we would not be able to offer the Program without it.

How We Protect the Information

We are committed to protecting the confidentiality of your information. Our systems are designed with your security and privacy in mind. We take reasonable measures to secure your information, including industry standard administrative, physical and technical controls. These controls include encryption, third party audits, access controls and security testing, below there are some significant controls:

• We work to protect the security of your personal information during transmission by using encryption protocols and software.
• We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.
• We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of customer personal information. Our security procedures mean that we may ask to verify your identity before we disclose personal information to you.
• It is important for you to protect against unauthorized access to your password and to your computers, devices, and applications. We recommend using a unique password for your Health Wellness Travel and Leisure Inc. account that is not used for other online accounts. Be sure to sign off when finished using a shared computer.

International Transfers of your Personal Data

Your Personal Data may be transferred outside of your country of origin. We will store your Personal Data on servers located in the United States of America. If you are located in the UK or an EU member state, then this transfer is covered under standard contractual clauses between Health Wellness Travel and Leisure Inc. and Health Wellness Travel and Leisure Inc. (US). You have a right to obtain a copy of the SCCs on request.

Your Personal Data may be shared outside of the Health Wellness Travel and Leisure Inc. group as stated in the ‘Information We Share’ section above. Where we work with service providers, your Personal Data may be transferred to countries outside of the country of origin, which may not have equivalent standards of data protection under their legislation. On these occasions, we take steps to protect the data as required, including under European data protection laws by executing European standard contractual clauses and/or by requiring those processors to adhere to the SCCs. While the data is stored in the US it may be accessed by US law enforcement or national security agencies. Government requests for data will be assessed and challenged, if determined to be unlawful or disproportionate.

Cookies

We use cookies to provide you with the best experience while using the Program, to manage your browser sessions and to power the Program’s functionality. For more information, please see our Cookie Policy. Cookies allow you to use all of the Program’s functions as designed. Disabling cookies will limit functionality of the Program and significantly degrade the user experience.

Some third parties (e.g., advertisers, tracking utilities) use cookies and Web beacons on their site(s). We do not have access or control over these tracking technologies. We do not share your personally identifiable data with these advertisers.

This Privacy Policy covers our use of cookies on the Program and the private label subdomains delivered by us, only. This Privacy Policy notice does not cover the use of cookies by any third parties.

Email Marketing

We do not send unsolicited marketing emails to individuals without prior consent. We send pre-registration emails at the request of your organization in order to invite you to join service. You may manage the way in which you will receive correspondence, including email reminders, newsletters and Program updates using the “My Account” section of the Program.

Opting Out

All marketing emails sent by us relating to the Program contain instructions on how to unsubscribe from future correspondence. You may opt out of marketing correspondence relating to the Program by visiting the Contact Us page or by clicking on the unsubscribe link in the marketing email. Users may also access and edit their personal information in the “My Account” section of the website. You can change your communication preferences at any time. You will continue to receive operational emails relating to the Program unless you choose to unsubscribe from the Program.

If you would like your personal information, including email address, to be completely removed from Our database, you should use the Contact Us page. We will respond to your request within thirty (30) business days. Completely removing your personal information from the database will negate your ability to login and use to the Program.

Personal Data and rights for UK and European Economic Area Residents

Residents of the EU and United Kingdom are afforded certain rights under European and UK Privacy law We will comply with your rights and fulfill any requests made by you under this section in accordance with applicable data protection laws.

To submit a request to exercise your rights under UK or EU General Dara Protection Regulation (GDPR), please see the Contact Us page or contact Info@HealthWellness TravelandLeisureInc.com.

The rights that apply to European Economic Area Residents are summarized below:

Request Access to Data (Right to information)

You are entitled to request confirmation as to whether Personal Data concerning you is being processed and, if so, to obtain a copy of your Personal Data held by us. You may also obtain a description of how your Personal Data is used and whether it has been onward transferred and, if so, information on the recipients or categories of such recipients.

To comply with the SCCs (as referenced above in the section “International Transfers of Your Personal Data”), we may need to notify and obtain authorization from your organization prior to responding to any data subject access request.

Correcting Personal Data (Right to Rectification)

You are entitled to request that any incorrect Personal Data that we hold is corrected. You can also make these changes yourself, through the ‘My Account’ page.

Deleting Person Data (Right to Erasure)

You are entitled in certain circumstances to request that some or all of your Personal Data is deleted. If you request that all of your Personal Data is deleted we will close your account and you will no longer be able to access membership.

Objecting to or limiting our use of your Personal Data (Right to Object to Processing)

You can ask us to stop using some or all your Personal Data in certain circumstances, including where you exercise your right to object to the processing of your personal data based on our legitimate interests.

Transfer of Your Data (Right to Data Portability)

You are entitled to request a copy of the Personal Data that you provided in machine readable form.

Personal Data and Rights for California Residents

Residents of California are afforded certain rights under California Privacy law. We will comply with your rights and fulfill any requests made by you under this section in accordance with applicable data protection laws.

To submit a request to exercise your rights under the California Privacy Rights Act (CPRA), please see the Contact Us page or contact Info@HealthWellnessTravelandLeisure Inc.com.

The rights that apply to California Residents are summarized below:

Right to Know

You are entitled to know about our data collection practices, including:

• The categories of personal data collected about you;
• The categories of sources your personal data are collected from;
• The categories of third parties your personal data is shared with;
• The business reasons personal data is collected; and
• The specific personal data collected about you.

Right to Deletion

You are entitled in certain circumstances to request that some or all your Personal Data is deleted. If you request that all of your Personal Data is deleted we will close your account and you will no longer be able to access membership.

Right to Know if We Sell Your Personal Data and to opt Out

You are entitled to know if we sell your personal data or disclose it for other valuable consideration, and to whom.
Health Wellness Travel and Leisure Inc data or to sell your personal data or disclose it for other valuable consideration under any circumstances.

Right to Access Your Personal Data

You may have the right to request information about the collection of your personal information by Health Wellness Travel and Leisure Inc. You are entitled to request a copy of your personal data.

Right to Non-Discrimination

You are entitled to equal service and price, even if you exercise your privacy rights.

Verification of Consumer Requests

We only required to respond to a request upon a consumer request. Under certain circumstances, we may request additional information from you to verify your identity. We regularly review our customer accounts as part of compliance with customer account verification requirements. You may have the option to submit a consumer rights request through your password-protected account. To allow us to verify your account, please log in  and go to the section Contact Us, follow the instructions and submit your request. We could use a combination of the following information as an additional verification method to verify the user identity:

• First and last name
• Account number
• Email Address
• Shipping Address
• Billing Address
• Purchase History

If you don’t have the information available or can’t access to your account, we may verify your identity by requiring you to provide evidence that matches the personal information maintained by us. If we are unable to verify a user request, we may deny the request.

Personal Data – Retention Period

We will store your Personal Data while you remain registered as a user of membership. If you unsubscribe from mailing, we will close your account, and your Personal Data will be deleted from our database based on our retention policy. We will retain your Personal Data even after we have closed your account to the extent necessary to comply with our legal obligations, to resolve disputes, and to fulfil your request not to receive further communications from us.

Merchant’s Privacy Policies

Many offers on the Program will redirect you to a participating retailer’s web site. An interstitial page will be displayed that will inform you that you are being redirected. At this point you will be on the merchant web site and the merchant’s privacy policy will then apply to any information you provide. It is important to read and familiarize yourself with the merchant’s privacy policy.

Community Online Academy

YouTube

Health Wellness Travel and Leisure Inc. uses YouTube to display video content of past sessions. YouTube incorporates tracking technologies, which may be present in the YouTube videos embedded on the COA home page, which may collect information from your browser when you view the video, including device identifiers and/or cookie IDs. This information is collected directly and automatically by YouTube and its partners, and Health Wellness Travel and Leisure Inc. does not participate in these data transmissions. Health Wellness Travel and Leisure Inc. does not provide any Personal Information, such as usernames, to YouTube.

Children’s Privacy Policy

• Attendance to Community Online Academy – No Child Attendee shall be allowed to join any session run during a COA without parental consent being provided.
• Giving Parental Consent – Upon activation of your account such that you are able to access a session run under the Community Online Academy, you shall in turn be providing consent for any minor that is under your legal guardianship who may attend a session. Through providing consent you shall in turn agree to the COA Marketing clause.
• In relation to Child Attendees from UK and European Economic Areas – In accordance with the General Data Protection Regulations, all parental guardians of child attendees reserve the right to remove their child’s images and audio recording from any promotional material made by Health Wellness Travel and Leisure Inc. in relation to COA.
• In relation to Child Attendees from California – In accordance with the California Consumer Privacy Act, all parental guardians of child attendees reserve the right to remove their child’s images and audio recording from any promotional material made by Health Wellness Travel and Leisure Inc. in relation to COA.

Marketing

Health Wellness Travel and Leisure Inc. reserves the right to use data and information that is generated vis-à-vis to any COA sessions that you attend for the creation and sharing of marketing material. This material can be distributed across various social media platforms such as but not limited to; Instagram, Facebook, LinkedIn and Twitter.

Complaints and Dispute Resolution Process

If you have questions or concerns regarding this Privacy Policy, or Health Wellness Travel and Leisure Inc.’s privacy program, please submit your enquiry through the Contact Us page. You can also contact us at Info@HealthWellnessTravelandLeisure.com

Health Wellness Travel and Leisure Inc. will respond to any such inquiries or complaints within forty-five (45) days. In the event that Health Wellness Travel and Leisure Inc. fails to respond or its response is insufficient or does not address the concern, Health Wellness Travel and Leisure Inc.  

Health Wellness Travel and Leisure Inc. will cooperate with the United States Federal Trade Commissions and any data protection authorities of the EU Member States (“DPAs”) in the investigation and resolution of complaints that cannot be resolved between Health Wellness Travel and Leisure Inc. and the complainant that are brought to a relevant DPA. If your inquiry has not been satisfactorily addressed, you may initiate a dispute resolution process.

If you are a citizen of the UK or European Economic Area, you should contact the ICO as the competent supervisory authority via its website at https://ico.org.uk/. However, we would request that you contact our Data Protection Officer before making a formal complaint.

Health Wellness Travel and Leisure Inc. commits to periodically reviewing and verifying the accuracy of this Privacy Policy and its compliance with all applicable data privacy legislation, and remedying issues identified.

Notification of Changes to the Privacy Policy

This Privacy Policy may be reviewed and amended from time to time. You will be notified of changes to this Privacy Policy by a notice posted on the Program login page. The notice will contain a link, whereby the amended privacy policy can be examined in full. In this way, you will be made aware of policy changes prior to browsing or shopping on the Program. We may e-mail periodic reminders of our notices and conditions, but you should check our website frequently to see recent changes. As always, if you are not amenable to the conditions of a revised privacy policy you may opt out of the Program by the means outlined earlier in the ‘Opting Out’ section above.

In Summary

Health Wellness Travel and Leisure Inc. is committed to protecting your privacy. We do not sell, trade, give away, or rent personal information to any third parties in ways other than disclosed in this Privacy statement. We use the information collected while you are using the Program in order to make shopping and promotional activities possible and enhance your overall experience of the Program.

Contact Us

We provide several methods for corresponding with us. Please direct your questions or comments to:

1. Contact Us page
2. Data Protection Officer

The Data Protection Officer of Health Wellness Travel and Leisure Inc. Limited may be reached by contacting privacy@HealthWellnessTravelandLeisure.com.