Thrive Tribe is 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.
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 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.
To enable Gloji to deliver its services, we may share your personal data with internal or external third parties including our referring partners for the purposes of carrying out the services that we have contracted with them to provide us, in accordance with Gloji’s terms and conditions and subject to strict data privacy terms. A current list of such third parties is listed at:
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.
You have the right to withdraw consent at any time by contacting us at firstname.lastname@example.org.
We may if you have opted in to receive marketing messages recommend complementary or additional services offered by us or by our trusted partners. 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.
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. Our primary data storage and primary backup are located in the United Kingdom.
We take reasonable administrative, physical and electronic measures designed 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.
Exceptionally, the data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom or the European Union (“EU”). It may also be processed by staff operating outside the EU who work for us or one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. We will always ensure that any processing in third countries is in full accordance with relevant data processing legislation.
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.
“Cookie” is used as a blanket term for all cookies, tags, trackers, pixels, beacons and other similar technology whether placed by ourselves or by third parties, which may be stored on your browser or the hard drive of your computer and which contain information that is transferred to your computer’s hard drive. Our approach, using our cookie consent solution is to:
With the exception of strictly necessary cookies, which do not store any personally identifiable information and which are essential to the operation of the whole or specific parts of the Site, our solution allows you to select and manage your cookie preferences, and to prevent cookies from deploying until you have actively consented to their use. If you wish to change your cookie preferences at any time, please click on the cog icon at the bottom left of your screen when visiting https://www.gloji.co.uk/.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements in accordance with our records management policy which is available upon request. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or to fulfil our audit and reporting purposes. Unless any such specific circumstances apply, we will wipe your personal data collected via the app on your terminating your use of Gloji.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may:
If you wish to exercise any of the rights set out above, please contact email@example.com.
You will generally not have to pay a fee to access your personal data (or to exercise any of the other rights).
If you believe that we have done something wrong by not complying with GDPR, please contact us in the first instance to make a complaint for which we aim to resolve.
Should you not be happy with this resolution, you do have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office. Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline number: 0303 123 1113. This policy was last updated in March 2022 .
You have the right to withdraw consent at any time by contacting; gloji at firstname.lastname@example.org
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