PHI MARKETING POLICY – December 2023

Being transparent and providing accessible information to individuals about how we will use their personal data is a key element of the Data Protection Act 1998 (DPA) and the EU General Data Protection Regulation (GDPR) May 2018.

The first principle of data protection is that personal data must be processed fairly and lawfully. The DPA says that in order for the processing to be fair, the data controller (Ori Wellness) has to make certain information available to the data subjects (the individuals whom the data relates to), so far as practicable.

The code of best practice uses the term ‘privacy notice’ to describe all the privacy information that we make available or provide to data subjects when collecting information about them. For simple terms, please refer to the relevant privacy notice for the services you are requesting, which sets out the following criteria:

• What information is being collected.
• Who is collecting it.
• Why is it being collected.
• How will it be used.
• Who will it be shared with.
• Right of access to data
• Methods for un-subscription

These techniques allow us to give data subjects greater choice and control over how their personal data is used and demonstrates that we are using personal data fairly and transparently.

In broader terms, an individual’s data will be collected to administer the products, services or information requested.

Phi Marketing collects data for the purpose of legitimate interest and this may include (but not be limited to) title, first name, surname, address, telephone numbers, email address and where provided, status of health, age and gender.

Once data has been collected it will be stored in a secure database and will only be used to confirm reservation and pre-arrival details, to complete transactions for purchases, to advise of offers/promotions or any other relevant information in administrating and fulfilling requests.

Data will be retained for a period of time that is deemed suitable for the purpose of being relevant, which may vary according to the services requested.

Personal data will not be shared, sold or passed to third parties for any marketing purposes. We may give access to your information to our service providers in order to fulfil activities e.g. data cleansing and distribution, on our behalf. In such instances we only disclose information necessary to deliver the service required and we have a contract in place that states that our partners must keep information secure and confidential, and cannot use it for their own marketing purposes.

Data subjects have a right of access to the data we hold and should contact us in writing with any requests for access. Data subjects may also exercise their right to erasure provided they do so in writing, including any evidence or proof why we should no longer hold their data.

All requests will be considered and a response given within 72 hours. In exceptional cases, we may not agree to full erasure if a legitimate/legal reason for doing so exists.

People’s expectations about personal data are constantly changing and data subjects are increasingly willing to share information on social media platforms. Where data has not been consciously provided by data subjects in this way, the requirement to be fair and transparent still arises. In such cases we will continue to be transparent about the processing of data and comply with the legal requirements to provide privacy information via our

Privacy Impact Assessment (PIA). This is a methodology for assessing and mitigating the privacy risks involving personal data.

We will also consider the effect of our processing on the data subjects concerned to include the following main elements of fairness:

• Using information in a way that people would reasonably expect.
• The impact of processing data and any unjustified adverse effects for the individual.
• Being transparent and ensuring that people know how their information will be used.
• What will be the effect of this on the data subjects concerned.
• Is the intended use likely to cause data subjects to object or complain.

We will ensure that data subjects are given appropriate control and choice. Where we need consent from an individual in order to process their information we will explain what we are asking them to agree to and why. To comply with the code, we will also make sure that where people do have a choice, they are given a genuine opportunity to exercise it and it will be given freely, be specific and allow the individual to be fully informed.

Consent will also be revocable.

Use of cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally. Please note that cookies can’t harm your computer and don’t store personally identifiable information. These pieces of information are used to improve services for you through, for example:

• Enabling a service to recognise your device so you don’t have to give the same information several times during one task
• Recognising that you may already have given a username and password so you don’t need to do it for every web page requested measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast.

We will not use cookies to collect personally identifiable information about you, but you may wish to restrict or block the cookies which are set by our websites, or indeed any other website and you can do this through your browser settings. The ‘Help’ function within your browser will tell you how, but you can also visit www.aboutcookies.org which contains comprehensive information on how to do this and also information on how to delete cookies as well as more information about cookies.

Please be aware that restricting cookies may impact on the functionality of any website.

If you wish to opt-out of third-party website owners collecting any statistical visit data regarding your interaction on our website, please refer to their websites for further information – Facebook, Google etc

Cookie Policy for Phi Marketing

This is the Cookie Policy for Phi Marketing, accessible from www.phi-marketing.co.uk

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the sites functionality.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies. This Cookies Policy was created with the help of the Cookies Policy Generator.

The Cookies We Set

• Account related cookies
• If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.
• Login related cookies
• We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
• Orders processing related cookies
• This site offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
• Site preferences cookies
• In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

• This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
• For more information on Google Analytics cookies, see the official Google Analytics page.
• The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.
• For more information on Google AdSense see the official Google AdSense privacy FAQ.
• We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; {List the social networks whose features you have integrated with your site?:12}, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
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More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.

However if you are still looking for more information then you can contact us through one of our preferred contact methods:

• Email: contact@phi-marketing.co.uk