Effective Date: 25/03/25

1. WHAT DOES THIS NOTICE COVER?

This notice describes how From Within Retreat Limited. (collectively, “From Within”, “we”, or “us”) processes your personal data in connection with your use of our website www.fromwithin.uk (the “From Within UK Site”). This includes when you participate in the promotional prize draws (the “Prize Draws”) offered on our Platform, sign-up for emails or text messages, or contact us. This notice also describes your data protection rights, including a right to object to some of the processing that From Within carries out on our Platform. More information about your rights, and how to exercise them, is set out in the “What rights do you have?” section. From Within Retreat Limited is the controller for the personal data we collect in this context.

2. WHAT INFORMATION DO WE COLLECT?

We collect and process personal data about you when you interact with us or use our Platform, and when you participate in the Prize Draws. This includes:

• Where you set up an account, sign-up for emails or text messages, or complete a transaction:
  • name;
  • contact information, such as postal address, email address, and telephone number;
  • your payment and delivery details for any purchase, including billing addresses and payment card details (note that your payment card details are processed by our third-party payment vendor);
• Where you interact or engage with our Platform, marketing communications and other content:
  • your marketing preferences, including any consents you have given us (where applicable);
  • information related to the browser or device you use to access our From Within UK Site;
  • the information about how you use the From Within UK Site and other websites visited/clickthroughs beforehand;
  • any marketing calls that we and/or third parties acting on our behalf make to you (may also be recorded for record-keeping, training and quality purposes.
• Where you interact with our customer services team:
  • name;
  • contact information;
  • details of any complaint or query or support request;
  • when you interact with our customer services team by phone, calls may be recorded for record-keeping, training and quality purposes;
• Where you voluntarily participate in any surveys:
  • survey information such as shopping habits, age, gender, income, or other survey data you may choose to provide us or our third party review platforms if you participate;
• Where you win a Prize Draw:
  • any personal data necessary to grant the prize (e.g., information included as part of necessary background checks);
  • photographs, video recordings, and information when you choose to provide that information.

3. HOW DO WE USE THIS INFORMATION, AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We process personal data for the following purposes and legal bases:

• To fulfil a contract or take steps linked to a contract. Where you enter a Prize Draw, we will use your information:
  • to verify your identity;
  • to take payments;
  • to communicate with you as is necessary to perform our obligations to you, including sending you automated service messages;
  • to provide customer service;
  • to draw the winners; and
  • to arrange the delivery or other provision of prizes for the winners of the draw.
• As required by From Within Retreat Limited to conduct our business and pursue our legitimate interests, we will use your information:
  • to provide products and services you have requested;
  • to securely deliver and effectively administer our Platform including showing you the correct notices and information and troubleshooting any system errors;
  • to carry out insight and analytics to help us monitor, develop, improve, and protect our products, content, services, and the Platform, both online and offline;
  • to investigate and respond to any complaints received from you or from others, about the Platform or our products or services;
  • where you have transacted with us, to send you direct marketing (e.g. email or text message) in relation to our current activities, future events and Prize Draws. You can opt out of this marketing (i) at the time of the collection of your details, (ii) by using the links within the marketing communications or (iii) by contacting us;
  • to personalise the Platform, our products or services, marketing communication for you;
  • to engage in targeted advertising activities to show you advertisements tailored to your individual interests on the Platform, selected partner sites and social networks;
  • to find prospective customers who share existing customers’ demographic/interests/likes etc to serve them with targeted advertising;
  • to measure the impact and effectiveness of our advertising strategies;
  • to process payment card details, payments and check the validity of the sort code, account number and card number you submit in order to prevent fraud (which is processed by our third party payment vendor);
  • to contact you about your subscription, including to remind you that your subscription is about to renew to inform you of any issues processing your subscription payments,
  • to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
  • to provide the prize to winners;
  • in connection with legal claims, compliance, regulatory, and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
  • to invite individuals to take part in market research;
  • in connection with those cookies and similar technologies that are strictly necessary to make the From Within UK Site function and
  • for record-keeping, training and quality purposes to improve the level of customer service that we provide. If you interact with our customer service team by phone (for example if you contact us with a query or if we contact you about your subscription), calls may be recorded for these purposes.
• Where you give us consent, we will use your information:
  • where you have signed up to our mailing list, to send you direct marketing in relation to From Within products and services, including emails and/or text messages;
  • in connection with surveys, where you choose to participate in those surveys and choose to provide us any information;
  • in connection with cookies and similar technologies that are not strictly necessary for the Platform to function, which technologies we may use to collect or receive information from your websites and elsewhere on the Internet and use that information to provide measurement services and target ads about From Within and the information provided to you when those technologies are used;
  • enable special features within our Platform such as push notification reminders, alerts, updates and other information.
  • in connection with photographs, video recordings and information about you if you attend the Retreat or win a Prize Draw and choose to provide that information; and
  • to use on other occasions the data for the purpose that we explain at that time we seek your consent.
• For purposes which are required by law, we may use your information:
  • In response to requests from government or law enforcement authorities conducting an investigation or courts

4. WHO DO WE SHARE YOUR DATA WITH?

When processing your personal data, we may need to share it with the following third parties:

• Our other group companies, where this is necessary to operate our business.
• Third party service providers, who will process it on behalf of From Within for various operational purposes (such as website hosting, maintenance, card processing services, email communication services, and telephone communication services).
• We may use third party telephone answering service providers to assist with the handling of customer calls to our call centre and enable our customers to communicate more easily with us over the phone. We may also use third party service providers to make outbound customer calls to customers who are experiencing problems with their subscription or payments so that these issues can be quickly resolved, and ensure these customers can maintain eligibility for ongoing prize draws where they wish to do so. Calls to and from these third parties may be recorded for record-keeping, training and quality purposes.
• Personal data of winners may be shared for the purpose of fulfilling the Prize Draw, including as part of a necessary background check or as part of preparing any required documents. With permission, personal data for winners may also be shared publicly on the Platform or other outlets, for the purposes of publicising who won the Prize Draws, including names, photographs, and videos.
• Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Please note that if you post a comment to the Platform or other social media sites, the information that you choose to post, including any personal data that you choose to post, may be available generally to the public.

5. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING OR OTHER TECHNOLOGIES

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. For example, you may opt-out of emails and/or text messages at any time.

With regard to cookies or other tracking technologies, you can adjust your cookie settings in our Cookie Settings. You can also set your browser to refuse all or some browser cookies or alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly

To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

You may be able to opt-out of receiving certain personalised advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt-out directly from providers who participate in those programs. You may also be able to adjust your settings regarding personalised advertisements by adjusting the privacy settings in the applications and/or social media platforms you use. Please note that From Within does not control or operate these tools or the choices that advertisers and others provide through these tools.

6. WHAT RIGHTS DO YOU HAVE?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this data to another controller; and withdraw your consent, if we rely on it as our legal basis for processing your personal data.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU or UK data protection authority where you live, work or where you believe a breach may have occurred. In the UK, the data protection authority is the Information Commissioner’s Office.

7. HOW DO YOU GET IN TOUCH WITH US?

We hope that we can satisfy queries you may have about the way we process your data and any of the details listed above.

If you have any other questions or concerns, you can get in touch with us at connect@fromwithin.uk , or by writing to 49 Bassett Road, Wednesbury, WS10 0HW.

8. HOW LONG WILL WE RETAIN YOUR DATA?

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.

Where we process From Within account data, we do this for as long as you are an active user of our Platform and for 6 years after this. 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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process personal data in connection with processing your contest entry, we keep the data for up to 6 years from your last interaction with us.