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Privacy

Gloji is provided by Thrive Tribe Limited. Thrive Tribe (“We” or “Us”), respects your privacy and is committed to protecting your personal data. We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.   

This privacy policy supplements other notices and privacy policies and is not intended to override them.  

Thrive Tribe and Gloji are a health and wellness provider that delivers interventions such as weight management, smoking prevention, mental wellbeing, NHS health checks, workplace health, physical activity and training via face-to-face, remote and digital avenues via the web-based app referred to as “Gloji” in the remainder of this policy. By using Gloji, you will be entrusting your personal data to us, and some of that data will fall within the special categories of data listed at [Article 9 General Data Protection Regulation (GDPR], because it relates to your health and wellbeing. The specific program developed by us will reference specific conditions, including weight. This program may expand and develop further over time so that additional features become available for access. 

For that reason, we ask you to formally assent to this privacy policy by clicking on the link embedded at the website when signing up to the app for the first time and the basis on which we will process the special categories of data will be your explicit consent. Although you may withdraw your consent at any time by notice in writing to us, you should be aware that because of the nature of Gloji, which provides 1:1 telephone support upon your request and is personalised based on any specific health conditions disclosed by you, it is not possible for you to continue to use Gloji unless we are able to process the special categories of data to do so.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  

Where we need to collect personal, sensitive and special category data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with personalised 1:1 telephone support, as further set out in Gloji’s terms and conditions).

Inputting inaccurate or incomplete data may also render our services less effective for you. 

How we use your personal data

By signing up for Gloji, you are therefore consenting for us to provide you with a healthcare service. In order to help us deliver that healthcare service, we may share your personal data with internal or external third parties including our referring partners, NHS (National Health Service), Public Health England, funding bodies, local authorities and health care professionals for the purposes of carrying out the services that we have entered into a contract with them to deliver. 

Although we will only refer your data to the specific body or bodies relevant to your area. We do not allow any third-party service provider to use your personal data for their own purposes and only permit them to process your personal data for the specified purposes as provided with our instructions.

Our website and webapp may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Such websites operate their own privacy policies which are in no way associated with Gloji. We will not share your personal data with any third-party website you choose to visit as a result of using Gloji. We advise that you check any third-party privacy policy before you submit any personal data as these will vary from Gloji’s privacy policy.

You have the right to withdraw consent at any time by contacting us at support@gloji.co.uk.

Marketing 

If you have opted into receiving marketing communications we recommend third party services to you. We do not allow advertising companies to collect data through our service for ad targeting. 

We will only use your data for the above marketing purposes if you have selected your marketing communication preferences by selecting SMS, Email or Phone checkbox on the marketing consent screen.

You can also exercise the right to remove your consent to the processing of your personal data for marketing purposes at any time by contacting us using our usual methods.

How we store your personal data 

We take data security very seriously. Your personal data is stored in line with Thrive Tribe’s Record Management Policy, which is available upon request and is aligned to the requirements set out in the NHS Records Management Code of Practice for record management and retention. Our data storage and backup storage are both located in the United Kingdom. 

We take all administrative, physical and electronic measures necessary to safeguard and protect your information from unauthorized access or disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which encrypts the personal information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network.  We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

By submitting your personal data, you agree to this transfer, storing or processing. 

All information you provide to us is stored on our servers (see above: Information we may collect from you). Any payment transactions will be encrypted using SSL technology, and processed by an external payment processor. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Data retention 

We retain your personal data inline with the requirements set out in the NHS Records Management Code of Practice for record management and retention. You can request a copy of our data rention policy by emailing support@gloji.co.uk.

Notwithstanding the foregoing, we reserve the right to aggregate your personal data with other data from participants in the Gloji programme (so that it can no longer be associated with any individuals) for research or statistical purposes and for the purpose of reporting trends and performance against milestones. Such aggregated data will not longer constitute personal data and we are therefore permitted to use it indefinitely without further notice to you. 

Your rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may: 

– Request access to your personal data  

– Request correction of your personal data  

– Request erasure of your personal data  

– Object to processing of your personal data  

– Request restriction of processing your personal data  

– Request transfer of your personal data  

– Right to withdraw consent  

If you wish to exercise any of the rights set out above, please contact support@gloji.co.uk.

You will generally not have to pay a fee to access your personal data (or to exercise any of the other rights). 

Contact details 

You have the right to withdraw consent at any time by contacting; gloji at support@gloji.co.uk.

Full legal entity details: 1st Floor office, Kesslers Building, 11 Rick Roberts Way, London, E15 2NF Telephone: 020 3434 2520

Gloji is registered with the ICO number ZA114260.