PRIVACY POLICY

This is the Privacy Policy for Nordic Cuddle Limited, with registered address, International House, 64 Nile Street, London, N1 7SR, United Kingdom ("Nordic Cuddle", "us", "we" or "our"). It explains how we, as data controller, collect, use and share the information that we receive or collect about you (that may include personal information) though our website www.nordiccuddle.com (referred to as "the Site") which you can use to book cuddle therapy sessions (referred to as "the Services"), and through other interactions with us that you may have during the course of our various marketing and other activities. It also explains the rights you as a user of our Services have to control the use of your information. Personal information means any information relating to a natural person that allows that individual to be identified either directly or indirectly from that information. In this Policy we distinguish between users of the Services on whose behalf cuddle therapy session bookings are made, who we refer to as "Users" and users of the Services on whose behalf we offer the cuddle therapy sessions who we refer to as practitioners.

Please read this Privacy Policy carefully before you start using the Website.

1. Information we collect about you

Our primary goals in collecting information are to provide our Services to our Users and Practitioners and to enable us to best respond to our Users and Practitioners' requests for help or information and to improve our Services and their features and content and to promote our Services through our website and through our events, newsletters, and promotions where we have your permission to do so.

Categories of Information we collect from you:

Relating to both Users and Practitioners

  • Identity data - information used to identify users including first name and last name

  • Contact data - postal address (only where home sessions are requested), email address, telephone number and mobile number

  • Technical data - internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used by the user to access your website.

  • Marketing and communications data - User and Practitioner preferences in receiving marketing from Nordic Cuddle and any third party affiliates.

  • Operational data - including interaction with the Services

  • Aggregated data - data that is collected, used and shared such as statistical or demographic data for any purpose, eg. used to analyse trends, and to gather information on our User base as a whole. Or, in the case of Practitioners we may collect data such as number of bookings and schedule information.

Relating to Users only:

  • Profile data -includes any information that you have made publicly available on our noticeboards or on social media networks

  • Service Notes - we may collect information about our Service delivery for example, instructions on how to access a building. You provide this information voluntarily. We pass this information on to Practitioners so that they can understand any specific access / similar requirements.

Relating to Practitioners only:

  • Assessment data - information on qualifications and certification of Practitioners, trade test assessment results, contact logs data, performance and ratings data and DBS checks.

  • Profile data - Photograph, profile description, location for sessions, availability and qualifications and experience

 

Information we may collect from you from your use of the Services:

We will use this information to administer the Services and for internal operations, including troubleshooting, data analysis, testing research and statistical survey purposes. We will also use this information to measure the effectiveness of how we present content and deliver our Services and how we market and advertise. It is always your choice whether or not to provide information.

 

Information we may collect from other sources or which is automatically collected:

Information may be gathered from our affiliates and third-party sources including without limitation our third-party service providers (such as events, marketing services and payment providers), publicly available data, other companies and referrals.

When you visit the Website we may automatically collect additional information about you, such as the type of internet browser or mobile device you use, any website from which you have come to the Website and your IP address (the unique address which identifies your device on the internet) and your operating system, which are automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.

2. Uses made of your information

We will use the personal information described above to:

  •  Enable us to process Users' bookings of cuddle therapy sessions on behalf of Practitioners, send confirmation of cuddle therapy session bookings or confirmation of cancellations of bookings, and to enable Users and Practitioners to access other information or assistance offered through the Services and which they request including but not limited to customer service requests or assistance with dispute resolution;

  •  To assess and verify qualifications and credentials of Practitioners and to create and maintain profiles of Practitioners;

  •  Analyse the use of the Services and the visits to the Site in order to improve our content and Services including research into our Users’ demographics and tracking of sales data;

  • Where you have not objected, send you information to Users and Practitioners which we think you may find useful or which you have requested from us, including marketing communications such as emails about the Services, special offers or promotions and events.

We may review, scan, or analyse your communications on Nordic Cuddle’s Site between the User and the Service provider for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. Occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on Nordic Cuddle’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

3. Purposes and Lawful Bases for which Nordic Cuddle uses your data

We have set out below a description of the ways we use your personal information, the category of information it comes under and the legal basis or bases which we rely on to process it, including where we are relying on our legitimate interests and identifying what those interests are. There may be more than one lawful basis on which we process your information depending on the specific purposes for which we are using the information. Where we rely on legitimate interests we are always careful to balance your privacy rights with those interests.

Please note that these are examples of the kinds of personal information we collect and of the uses we may make of it. We may from time to time collect other types of personal information including and not limited to information you voluntarily give us.

Please contact us if you need more information at contact@nordiccuddle.com.

User Information

Purpose

To process and deliver a cuddle session booking request from a User

To administer and protect the website and Services (including troubleshooting, data analysis, testing and system review)

To manage our relationship with Users by sending emails to confirm bookings for cuddle therapy sessions or cancellations of bookings

Asking Users to complete ratings reviews or feedback surveys on Practitioners

Inviting Users to take part in any promotions or events

 

 

To advertise and market our site and service to Users

To notify Users of any changes to our policies

 

To maintain a blacklist

To record cuddle session reports by Practitioners which could from time to time include health data

To record Service Notes which are used to provide information to Practitioners to deliver sessions

To gather location data on Users in order to inform the Practitioners of the location in which to perform the sessions for home visits

 

 

 

 

 

 

To provide mediation between User and Practitioner in the event of a User complaint of unsatisfactory session

Type of data

Identity, contact, profile data, assessment data, location data

Identity, contact, technical data

 

 

 

 

Identity, contact

Identity, contact, usage, profile data

 

Identity, contact, marketing and communications data

 

 

Marketing and communications data, aggregated data

 

 

 

 

 

Identity data, contact data

Identity data, contact data,

Session report data (which may include health data)

Information provided by users which may include access information

Identity data, contact data, Location data

 

 

 

 

 

 

 

 

 

Identity, contact, assessment

Lawful basis for processing

Necessary for delivering a session

In our legitimate interests to run our website, manage administration and IT services

Necessary for delivering sessions or informing of session cancellations

 

 

In our legitimate interests to understand how Users use, enjoy and rate the Services to ensure cuddle therapy session standards are maintained

 

With consent where required by law in or where Users have not objected; in the legitimate interests of the business to encourage Users to use the Services

 

With consent where required by law in or where Users have not objected the case of direct marketing email communications; in the case of analysis and evaluation of our Services and campaigns in the legitimate interests of the business to develop and grow

 

Compliance with a legal obligation

 

In the legitimate interests of the business

 

Consent is required from Users to collect Session Reports

 

 

In our legitimate interests to provide Services that are as efficient and smooth running as possible. This information is provided voluntarily.

Necessary to provide home visits for the User, in our legitimate interests to provide Services that are as efficient and smooth running as possible. If this is collected automatically through your device, you will be asked if you permit us access to your location. We need your location in order to inform the Practitioners where the session needs to be performed for home visits.

Necessary to fulfil the services for the User, in our legitimate interests to provide Services

Practitioner information

Purpose

To register a new Practitioner

To assign and transmit a cuddle therapy session booking to the appropriate Practitioner

To manage our relationship with Practitioners by sending confirmatory emails of bookings or cancellations with Users

To maintain profiles on Practitioners including photograph(s), profile descriptions, availability, location and experience and qualifications

 

Providing Practitioners with feedback from Users including reviews and feedback surveys

Inviting Practitioners to take part in any promotions or events

 

 

To advertise and market our website and Services

To notify Practitioners about any changes to our website, and /or Services

 

To notify Practitioners of any changes to our policies

To maintain a blacklist

 

To provide mediation between User and Practitioner in the event of a User complaint of unsatisfactory session

Type of data

Identity, contact, profile information, availability, location, experience and qualifications, photograph

Identity, contact, profile data, location data

 

Identity, contact

 

 

 

Identity, contact, profile data

 

 

 

 

Providing Practitioners with feedback from Users including reviews and feedback surveys Identity, contact, assessment, profile data

Identity, contact, marketing and communications data

 

 

Identity, contact, marketing and communications, aggregated data

Identity, contact data

 

 

Identity, contact data

Identity, contact

Identity, contact

Lawful basis for processing

Necessary for listing Practitioners, in our legitimate interests in operating our Services

 

Necessary for providing practitioners with session information, fulfilling our contract with the Practitioner by sending appropriate bookings

Necessary for the performance of a contract with the User, necessary for the fulfilment of a contract with the Practitioner

Necessary for the performance of a contract with the Practitioner and User, in our legitimate interests in maintaining and improving the running of the Services

Necessary for the performance of a contract with the Practitioner, in our legitimate interests in maintaining and improving the running of the Services

 

With consent as required by law, In the legitimate interests of the business to encourage Practitioners to use the Services

With consent as required by law, in the legitimate interests of the business to develop and grow

Necessary for the performance of a contract with the Practitioner and in the legitimate interests of the business to ensure the smooth running of the Services

Compliance with a legal obligation

 

 

In the legitimate interests of the business

Necessary to fulfil the contract for services for the User, in our legitimate interests to provide Services

4. How we may share your Information

  • In order to provide the Services, we may share the information Users provide with Practitioners to assist them in the providing the cuddle therapy sessions booked by Users.

  • In order to provide the Services, we may share the information Practitioners provide to Users to assist them in selecting a Practitioner to book a cuddle therapy session with.

  • In some cases, we work in partnership with other carefully selected companies, Business Partners, and from time to time, with your consent, we may send you information about these third-party Business Partners' selected products or services in our communications with you. We do not share your personal data with these third parties directly.

  • We may disclose aggregate statistics about visitors to the Website in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes.

  • In the event that we undergo re-organisation, or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

  • We may disclose your personal information if legally entitled or required to do so (for example if required by law or by a court order or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Site or Service, or the rights, property or personal safety of any person).

5. Information you may collect as a User or Practitioner

If you are a Practitioner, you are responsible for ensuring that you comply with applicable data protection law in respect of any personal information that you collect about Users in the course of your provision of the Services. Nordic Cuddle does not accept any responsibility for this processing of personal data.

If you are a User, you are responsible for any misuse of personal information that you may collect in the course of your receipt of the Services. Nordic Cuddle does not accept any responsibility for this processing of personal data.

6. Public forums

The Site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to Users and Practitioners. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal information.

7. Child safety

Protecting the safety of children when they use the internet is very important to us. Our Site and Services are not intended for nor directed towards children and we do not knowingly collect personal information from children. If you believe that your child may have provided us with personal information without your consent, you may alert us at contact@nordiccuddle.com.

8. External links

The Site may, from time to time, contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We have no control over these third parties and we are not responsible for the content of such websites or for the privacy policies or practices of such third parties. You should review the privacy policy of any third party website carefully that you visit.

9. Payment processing

All payments transactions made through the Services are conducted through our payment providers, such as Paypal. You will be providing credit or debit card information directly to these providers who process payment details and authorise payment.

10. Security

  • We place great importance on the security of all personal information associated with both Users and Practitioners. We have implemented appropriate technical and organisational measures to ensure the security of your information and to protect any personal information that is transmitted, stored or otherwise processed against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. In addition, we limit access to this information to only those who have a business need to know. They will only process it on our instructions and they are subject to a duty of confidentiality.

  • The safety and security of your personal information also depends on you. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site or the Services. It is also advisable to close your browser when you have finished your user session to help ensure others do not access your personal information.

  • Unfortunately, no electronic data transmission over the internet or storage of information can be guaranteed to be completely secure or error free and we therefore cannot warrant or guarantee the security of information you submit via the Site or Service transmitted to our Site or Service and any such submission is at your own risk.

11. Opting out

Where we have your consent, or where you have not objected to receiving (as applicable) we will use your personal information to send you marketing and promotional communications by email about our products/services or to send you feedback surveys and review requests on sessions provided. Where we partner and work with carefully selected Business Partners, our email communications may also contain information from our Business Partners.

You can object to further marketing communications at any time by clicking on the unsubscribe link included in each such communication or notify us by email at contact@nordiccuddle.com.

12. How long we keep your information

We need to retain your information (including your personal information, where applicable) for as long as you remain an active user of the Services in order for us to meet our contractual obligations to you, and for such longer periods as are legally required or permitted.

We may need to retain certain personal information even once a User account has been closed for differing periods, depending on the category of personal information concerned, for example, to enforce our terms, for fraud prevention, to identify, issue or resolve any legal claims, for proper record-keeping purposes and/or as required for our business operations or by applicable law.

We may also retain certain personal information following any objection indicated by you to receiving Nordic Cuddle marketing communications for the purpose of ensuring that your wishes continue to be respected and we do not to contact you further.

We may also retain aggregated information beyond this time for research purposes and to help us to develop and improve Services. You cannot be identified from aggregate information retained or used for these purposes.

13. Your rights

You have the right under certain circumstances:

  • To be provided with a copy of your personal information held by us;

  • To request the rectification or erasure of your personal information held by us;

  • To request that we cease processing your personal data in certain circumstances

  • To object to our processing of personal data for the purposes of sending you direct marketing emails;

  • To request that we restrict the processing of your personal information while we verify or investigate your concerns;

  • To withdraw consent where your personal information has been processed on this basis. You have the right to withdraw that consent without detriment by emailing us at contact@nordiccuddle.com or by clicking on the unsubscribe link found at the bottom of our emails;

If your request or concern is not satisfactorily resolved you may approach the local data protection authority. In the UK this is the Information Commissioner (https://ico.org.uk/).

14. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If a revision is material we shall notify you before they take effect either through the Site or by sending you a notification (as required). Any such material changes will only apply to personal information collected after the revised Privacy Policy takes effect.

15. Contact us

Please submit any questions or concerns regarding our Privacy Policy or any questions about the security of our Site or Services to: contact@nordiccuddle.com

This Privacy Policy was last updated on 11th March 2020.