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Privacy Policy

THE WELLNESS SYNDICATE

1. INTRODUCTION

Welcome to The Wellness Syndicate.

The Wellness Syndicate (“The Wellness Syndicate”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, share and protect your personal information when you:

  • visit or use our website;

  • create an online account;

  • apply to become a Member;

  • maintain a Membership;

  • purchase or receive products or services;

  • participate in Member benefits or loyalty programmes;

  • attend Member events;

  • participate in promotions, surveys or product feedback;

  • subscribe to our communications; or

  • otherwise interact with The Wellness Syndicate.

We process personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable South African laws.

By using our website or providing personal information to us, you acknowledge the processing practices described in this Privacy Policy.

Where your consent is legally required for a particular processing activity, we will request that consent separately.

2. WHO WE ARE

The Wellness Syndicate operates as a private membership-based wellness community.

For purposes of POPIA, the responsible party for personal information processed through our website, Membership programme and related services is:

The Wellness Syndicate

Legal Entity: [INSERT REGISTERED ENTITY NAME]
Registration Number: [INSERT, IF APPLICABLE]
Physical Address: [INSERT ADDRESS]
Email: [INSERT EMAIL]
Telephone: [INSERT NUMBER]

Information Officer

Name: [INSERT NAME]
Email: [INSERT PRIVACY EMAIL]

3. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed through:

  • The Wellness Syndicate website;

  • Member registration;

  • Member accounts;

  • online transactions;

  • Membership administration;

  • Member communications;

  • Member events;

  • loyalty and rewards programmes;

  • customer support;

  • surveys and feedback;

  • promotions;

  • physical Member facilities, where applicable; and

  • other services operated by or on behalf of The Wellness Syndicate.

Third-party websites and services may have their own privacy policies.

4. PERSONAL INFORMATION WE MAY COLLECT

The personal information we collect depends upon how you interact with The Wellness Syndicate.

We endeavour to collect only information that is reasonably necessary for a legitimate purpose connected with our operations.

4.1 Identification Information

We may collect:

  • full name;

  • date of birth;

  • age;

  • identity verification information;

  • Member number;

  • username; and

  • other information reasonably necessary to verify your identity or Membership eligibility.

Where age or identity verification is required, we will endeavour to collect only the information reasonably necessary for that purpose.

4.2 Contact Information

We may collect:

  • email address;

  • mobile or telephone number;

  • residential address;

  • delivery address;

  • billing address; and

  • communication preferences.

4.3 Membership Information

We may process information concerning:

  • your Membership application;

  • Membership status;

  • Membership tier;

  • joining date;

  • renewal date;

  • Member preferences;

  • Membership benefits;

  • loyalty rewards;

  • Member activity;

  • event participation;

  • account status; and

  • your interactions with The Wellness Syndicate.

4.4 Account Information

When you create an account, we may process:

  • username;

  • securely managed authentication information;

  • login activity;

  • account activity;

  • account preferences;

  • security information; and

  • records relating to suspected unauthorised access.

Members are responsible for taking reasonable measures to protect their account credentials.

If you believe that another person has obtained unauthorised access to your account, you should contact The Wellness Syndicate promptly.

4.5 Transaction and Payment Information

Where you purchase products, Memberships or services, we may process:

  • transaction amount;

  • transaction date;

  • products or services selected;

  • Membership package;

  • payment status;

  • billing information;

  • refunds;

  • cancellations; and

  • transaction references.

Payments may be processed by an authorised third-party payment provider.

Where a third-party payment provider processes your payment directly, The Wellness Syndicate may not receive or store your complete payment-card details.

4.6 Order and Delivery Information

Where products, Member benefits or other items are delivered or collected, we may process:

  • recipient name;

  • delivery address;

  • telephone number;

  • order information;

  • collection information;

  • delivery instructions; and

  • delivery or collection status.

4.7 Communications

When you communicate with us, we may retain information contained in:

  • emails;

  • contact forms;

  • customer-support requests;

  • complaints;

  • Membership enquiries;

  • surveys;

  • reviews;

  • feedback; and

  • other communications.

4.8 Event Information

If you register for or attend an event, we may process information relating to:

  • event registration;

  • attendance;

  • bookings;

  • Member eligibility;

  • guest information, where applicable; and

  • reasonable access-control or security requirements.

4.9 Website and Technical Information

When you use our website or digital services, certain technical information may be collected automatically.

This may include:

  • IP address;

  • browser type;

  • device type;

  • operating system;

  • pages visited;

  • referring website;

  • date and time of access;

  • website interactions;

  • session information; and

  • cookie or similar technology identifiers.

5. SPECIAL PERSONAL INFORMATION

Certain interactions with wellness-related services could potentially involve health information or other categories of special personal information.

The Wellness Syndicate does not intend to require Members to provide detailed medical information as part of ordinary Membership registration unless there is a legitimate and lawful reason for doing so.

Where special personal information is processed, we will process it only where permitted under POPIA and will take appropriate measures to protect it.

Members should avoid providing unnecessary medical, financial or other sensitive information through general contact forms, email or Member communications.

6. WHY WE PROCESS PERSONAL INFORMATION

We process personal information only where there is an appropriate purpose and basis for doing so.

Personal information may be processed for the following purposes.

6.1 Membership Administration

We may process information to:

  • receive and evaluate Membership applications;

  • verify Member eligibility;

  • verify age or identity where appropriate;

  • establish Member accounts;

  • administer Membership tiers;

  • process Membership fees;

  • manage renewals and cancellations;

  • administer Member benefits;

  • administer loyalty programmes; and

  • communicate important Membership information.

6.2 Providing Products and Services

We may process information to:

  • process orders;

  • provide requested services;

  • administer Member benefits;

  • arrange delivery or collection;

  • manage bookings;

  • facilitate Member experiences; and

  • provide customer support.

6.3 Processing Payments

Information may be processed to:

  • collect Membership fees;

  • process purchases;

  • administer recurring payments where authorised;

  • maintain transaction records;

  • process refunds;

  • identify payment failures; and

  • prevent fraudulent transactions.

6.4 Website Operation

Information may be processed to:

  • operate our website;

  • maintain Member accounts;

  • remember website preferences;

  • maintain website security;

  • troubleshoot technical issues;

  • understand website performance; and

  • improve our digital services.

6.5 Security and Fraud Prevention

We may process information to:

  • authenticate Members;

  • protect Member accounts;

  • detect suspicious activity;

  • investigate suspected fraud;

  • protect our website and systems;

  • maintain access controls;

  • protect Members and staff; and

  • prevent misuse of The Wellness Syndicate’s services.

6.6 Communications

We may use your contact information to send necessary communications regarding:

  • your account;

  • Membership;

  • transactions;

  • purchases;

  • bookings;

  • events for which you have registered;

  • security;

  • service interruptions;

  • changes to Membership;

  • changes to our legal terms; and

  • other important administrative matters.

These communications are distinct from optional promotional marketing.

6.7 Legal and Regulatory Requirements

Information may also be processed where reasonably necessary to:

  • comply with applicable law;

  • maintain legally required records;

  • comply with lawful requests;

  • establish, exercise or defend legal claims;

  • investigate suspected unlawful activity;

  • protect the rights of The Wellness Syndicate or others; and

  • comply with lawful regulatory requirements.

7. MARKETING COMMUNICATIONS

The Wellness Syndicate may communicate information concerning:

  • Member offers;

  • promotions;

  • products;

  • new services;

  • Member benefits;

  • private events;

  • loyalty rewards;

  • educational content;

  • newsletters; and

  • news from The Wellness Syndicate.

Where consent is required for direct electronic marketing, we will request that consent separately.

You may unsubscribe from marketing communications at any time by using the unsubscribe facility contained in the communication or by contacting us.

Unsubscribing from marketing communications will not necessarily prevent us from sending necessary communications regarding your Membership, transactions, security or account.

8. HOW WE COLLECT PERSONAL INFORMATION

We may obtain personal information in several ways.

8.1 Directly From You

For example, when you:

  • create an account;

  • apply for Membership;

  • complete a form;

  • make a purchase;

  • book or attend an event;

  • communicate with us;

  • participate in a promotion;

  • provide feedback;

  • subscribe to communications; or

  • update your Member profile.

8.2 Automatically

Certain technical information may be collected automatically when you use our website, Member portal or other digital services.

8.3 From Authorised Third Parties

We may receive limited personal information from service providers involved in providing our services.

These may include:

  • payment providers;

  • delivery companies;

  • technology providers;

  • identity or age-verification providers;

  • event providers; and

  • other authorised service providers.

We will process information received from third parties only where there is an appropriate lawful basis for doing so.

9. COOKIES AND SIMILAR TECHNOLOGIES

The Wellness Syndicate website may use cookies and similar technologies.

Cookies are small data files stored on your device that allow websites to recognise a browser or device and perform various functions.

We may use cookies for purposes such as:

  • maintaining website functionality;

  • keeping Members logged in;

  • maintaining shopping-cart functionality;

  • remembering Member preferences;

  • protecting website security;

  • understanding how visitors use our website;

  • measuring website performance; and

  • improving our services.

Some cookies may be necessary for the operation of the website.

Other cookies, including certain analytics or advertising cookies, may require consent.

Where legally required, optional cookies will only be used after appropriate consent has been obtained.

Additional information may be provided through our Cookie Policy and website cookie-management tool.

10. THIRD-PARTY ANALYTICS AND ADVERTISING

The Wellness Syndicate may use third-party analytics, advertising or marketing technologies on its website.

Depending upon the technologies implemented, these services may process information about:

  • website visits;

  • device information;

  • interactions with pages;

  • advertising interactions;

  • referrals; and

  • conversions.

Where these technologies require consent, they will be managed through our cookie-consent process.

The specific technologies actually used by The Wellness Syndicate should be identified in our Cookie Policy.

11. SHARING PERSONAL INFORMATION

The Wellness Syndicate does not sell Members’ personal information.

We may share limited personal information with third parties where reasonably necessary to provide our services.

These may include:

  • website hosting providers;

  • payment processors;

  • delivery and logistics providers;

  • IT providers;

  • cybersecurity providers;

  • email and communications platforms;

  • customer-support systems;

  • accountants;

  • auditors;

  • legal advisers;

  • event providers;

  • professional advisers; and

  • other service providers performing authorised functions on our behalf.

Where a service provider processes personal information on our behalf, we will take reasonable steps to ensure that appropriate privacy and security obligations apply.

We endeavour to provide third parties only with the information reasonably necessary to perform their services.

12. WE DO NOT SELL PERSONAL INFORMATION

The Wellness Syndicate does not sell, rent or trade Member databases or personal information to third parties for their independent marketing purposes.

Personal information obtained through private Membership will not be treated as a commercially available Member directory.

13. LEGAL DISCLOSURE

We may disclose personal information where disclosure is required or permitted by law.

This may include circumstances involving:

  • a lawful court order;

  • applicable legislation;

  • an authorised regulator or public authority;

  • investigation of suspected fraud;

  • investigation of unlawful conduct;

  • protection of our legal rights;

  • protection of another person’s rights or safety; or

  • establishment, exercise or defence of legal claims.

The private nature of Membership does not prevent The Wellness Syndicate from complying with lawful disclosure requirements.

14. INTERNATIONAL TRANSFERS

Some technology providers used by The Wellness Syndicate may operate or store information outside South Africa.

Where personal information is transferred outside South Africa, we will take reasonable measures to ensure that the transfer is handled in accordance with POPIA and applicable requirements relating to cross-border transfers.

15. INFORMATION SECURITY

The Wellness Syndicate takes reasonable technical and organisational measures to protect personal information against:

  • unauthorised access;

  • accidental loss;

  • unlawful processing;

  • misuse;

  • alteration;

  • unauthorised disclosure; and

  • destruction.

Depending upon the systems being used, safeguards may include:

  • access controls;

  • password protection;

  • authentication systems;

  • encryption;

  • secure hosting;

  • restricted administrative access;

  • system monitoring;

  • backups; and

  • appropriate security procedures.

No website, electronic communication or internet-based storage system can guarantee absolute security.

Members should therefore also take reasonable measures to protect their accounts, passwords and devices.

16. ACCOUNT SECURITY

Members must take reasonable steps to keep their login credentials confidential.

You should not knowingly provide your account password or authentication credentials to another person.

If you become aware of or reasonably suspect unauthorised access to your account, you should notify The Wellness Syndicate as soon as reasonably possible.

We may temporarily restrict or suspend an account where reasonably necessary to investigate suspected unauthorised access or protect the Member and our systems.

17. DATA BREACHES

If The Wellness Syndicate becomes aware of a security compromise involving personal information, we will take reasonable steps to:

  • investigate the incident;

  • contain the compromise;

  • mitigate potential harm;

  • determine what information was affected; and

  • improve relevant safeguards where appropriate.

Where notification is required by POPIA or other applicable law, we will notify the relevant authority and/or affected individuals as required.

18. RETENTION OF PERSONAL INFORMATION

The Wellness Syndicate will not retain personal information for longer than reasonably necessary unless continued retention is required or permitted by law.

The appropriate retention period may depend upon:

  • the duration of Membership;

  • contractual obligations;

  • transaction and payment records;

  • accounting requirements;

  • tax requirements;

  • security considerations;

  • fraud prevention;

  • dispute resolution;

  • legal claims; and

  • other applicable legal obligations.

Where personal information is no longer reasonably required, we will take appropriate steps to delete, destroy, de-identify or otherwise deal with it in accordance with applicable law.

19. YOUR PRIVACY RIGHTS

Subject to POPIA and applicable law, you may have the right to:

  • ask whether we hold personal information about you;

  • request access to your personal information;

  • request correction of inaccurate or outdated information;

  • request deletion or destruction of personal information in appropriate circumstances;

  • object to certain processing;

  • withdraw consent where processing is based upon consent;

  • object to certain direct marketing;

  • request information regarding certain third parties who have had access to your information; and

  • lodge a complaint with the Information Regulator.

These rights may be subject to limitations or exceptions contained in applicable law.

20. ACCESSING AND CORRECTING YOUR INFORMATION

Where available, Members may update certain information through their online account.

Alternatively, requests relating to your personal information may be submitted to:

The Wellness Syndicate – Information Officer

Email: [INSERT PRIVACY EMAIL]

We may require reasonable verification of your identity before granting access to, correcting or deleting personal information.

This helps prevent another person from improperly accessing or altering your information.

21. DELETION REQUESTS

You may request deletion or destruction of personal information where permitted under applicable law.

We may be required or permitted to retain certain information despite such a request, including where the information is reasonably required:

  • by law;

  • for tax or accounting purposes;

  • to complete an existing transaction;

  • to establish or defend legal claims;

  • to prevent fraud; or

  • for another lawful purpose.

Where information cannot immediately be deleted, we will process the request in accordance with applicable legal requirements.

22. CHILDREN AND AGE RESTRICTIONS

Membership of The Wellness Syndicate is intended for persons 18 years of age or older.

We do not knowingly accept Membership applications from persons under the applicable minimum age.

Where we reasonably determine that an ineligible minor has established an account, we may suspend or terminate the account and appropriately deal with the associated personal information.

23. MEMBER PRIVACY AND CONFIDENTIALITY

The Wellness Syndicate is intended to provide a private Member environment.

Members are therefore expected to respect the privacy of other Members.

Members may not improperly:

  • collect another Member’s personal information;

  • disclose another Member’s private information;

  • distribute Member contact information;

  • publish confidential Member communications;

  • scrape Member-only areas;

  • create databases from Member information;

  • use Member information for unauthorised marketing;

  • harass or unlawfully target another Member; or

  • otherwise misuse information obtained through Membership.

The private nature of the Member community does not limit any rights or obligations arising under POPIA or other applicable law.

24. PHOTOGRAPHY, VIDEO AND EVENTS

The Wellness Syndicate may occasionally photograph or record events, experiences or other activities.

Where photographs or recordings containing identifiable individuals are intended to be used for promotional or marketing purposes, appropriate notices and permissions will be obtained where required.

Members are also expected to respect the privacy of other Members.

Members should not photograph, record or publish identifiable private interactions where doing so would unlawfully interfere with another person’s privacy.

25. PRODUCT TESTING, SURVEYS AND FEEDBACK

Members may occasionally be invited to participate voluntarily in:

  • product testing;

  • surveys;

  • questionnaires;

  • research;

  • Member feedback;

  • product-development programmes; or

  • similar initiatives.

Where personal information is collected for these purposes, Members will be informed of the relevant purpose.

Additional consent or privacy notices may be provided where appropriate.

Participation in voluntary feedback or research programmes will not automatically be a condition of Membership unless clearly disclosed and lawfully permitted.

26. THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to third-party websites, platforms or services.

These third parties operate independently and may have their own privacy policies and terms.

The Wellness Syndicate does not control the privacy practices of independent third-party websites.

We encourage you to review their privacy policies before submitting personal information.

27. CHANGES TO THIS PRIVACY POLICY

The Wellness Syndicate may update this Privacy Policy from time to time.

Changes may be necessary because of:

  • changes to our website;

  • changes to Membership services;

  • new technology;

  • new service providers;

  • operational requirements;

  • regulatory requirements; or

  • changes to applicable law.

The latest version will be published on our website and identified by the “Last Updated” date at the beginning of this Policy.

Where a change materially affects how we process personal information, additional notice will be provided where appropriate or legally required.

28. CONTACT THE WELLNESS SYNDICATE

For questions about this Privacy Policy or the way your personal information is handled, please contact:

The Wellness Syndicate

Legal Entity: [INSERT REGISTERED ENTITY]
Information Officer: [INSERT NAME]
Privacy Email: [INSERT EMAIL]
General Email: [INSERT EMAIL]
Telephone: [INSERT NUMBER]
Physical Address: [INSERT ADDRESS]

29. INFORMATION REGULATOR

If you believe that The Wellness Syndicate has processed your personal information unlawfully, you may have the right to submit a complaint to the Information Regulator of South Africa.

The current official contact details of the Information Regulator should be obtained from the Information Regulator’s official website.

We encourage Members to contact our Information Officer first where appropriate so that we have an opportunity to investigate and respond to the concern.

30. WEBSITE PRIVACY ACKNOWLEDGEMENT

During account or Membership registration, the following acknowledgement may be displayed:

Required Privacy Acknowledgement

☐ I acknowledge that I have read The Wellness Syndicate Privacy Policy and understand how my personal information will be processed.

Optional Marketing Consent

Marketing consent should be presented separately from Membership acceptance:

☐ Yes, I would like to receive news, Member offers, promotions, product updates and event invitations from The Wellness Syndicate.

Members may withdraw marketing consent or unsubscribe from marketing communications at any time.

Declining optional marketing communications will not prevent a person from becoming or remaining a Member, subject to the applicable Membership requirements.

THE WELLNESS SYNDICATE

Privacy. Community. Wellness.