Privacy Policy of Whole In One Communion

Welcome to the privacy policy of Whole In One Communion. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.

Latest update: February 20, 2025

Summary

Data we collect automatically

We automatically collect data from you for example when you visit Whole In One Communion.

  • Usage Data
  • Trackers
  • answers to questions
  • clicks
  • +16

Trusted third parties help us to process it

How we use them

  • Displaying content from external platforms
  • Traffic optimization and distribution
  • SPAM protection
  • Advertising
  • Remarketing and behavioral targeting
  • Tag Management
  • Analytics
  • Interaction with live chat platforms
  • User database management
  • Platform services and hosting
  • Handling payments

Data you give to us

We collect the data you give to us for example when you interact with our online chat.

  • first name
  • last name
  • phone number
  • email address
  • +20

Trusted third parties help us to process it

How we use them

  • Contacting the User
  • SPAM protection
  • Registration and authentication provided directly by Whole In One Communion
  • Connecting Data
  • Managing contacts and sending messages
  • Interaction with live chat platforms
  • Advertising
  • User database management
  • Platform services and hosting
  • Handling payments

Owner and Data Controller

Whole In One Communion
ABN 71 215 656 649
19/593 Withers Road, Rouse Hill
NSW 2155

Owner contact email: privacy@whole-in-one.com.au

Type of Data we collect

Among the types of Personal Data that Whole In One Communion collects, by itself or through third parties, there are:

  • first name
  • last name
  • phone number
  • email address
  • Usage Data
  • Trackers
  • answers to questions
  • clicks
  • keypress events
  • motion sensor events
  • mouse movements
  • scroll position
  • touch events
  • billing address
  • number of Users
  • session statistics
  • company name
  • country
  • city
  • ZIP/Postal code
  • Data communicated while using the service
  • user content
  • contents of the email or message
  • profile picture
  • date of the message
  • time the message was sent
  • sender of the message
  • physical address
  • state
  • various types of Data
  • purchase history
  • shipping address
  • payment info
  • device information
  • financial information
  • product interaction
  • data relating to the point of sale
  • privacy choices
  • User ID
  • order ID
  • geography/region
  • time zone

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Whole In One Communion.
Unless specified otherwise, all Data requested by Whole In One Communion is mandatory and failure to provide this Data may make it impossible for Whole In One Communion to provide its services. In cases where Whole In One Communion specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Whole In One Communion or by the owners of third-party services used by Whole In One Communion serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Whole In One Communion.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Whole In One Communion (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

  • Contacting the User
  • Displaying content from external platforms
  • Traffic optimization and distribution
  • SPAM protection
  • Advertising
  • Handling payments
  • Registration and authentication
  • Registration and authentication provided directly by Whole In One Communion
  • Remarketing and behavioral targeting
  • Tag Management
  • Analytics
  • Connecting Data
  • Managing contacts and sending messages
  • Interaction with live chat platforms
  • User database management
  • Managing data collection and online surveys
  • Platform services and hosting
  • Managing support and contact requests

Detailed information on the processing of Personal Data

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Whole In One Communion, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Google Inc.

Google Ads conversion tracking

Company: Google Inc.

Place of processing: US

Personal Data processed: Trackers +1

Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on Whole In One Communion.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Meta Platforms, Inc.

Meta ads conversion tracking (Meta pixel)

Company: Meta Platforms, Inc.

Place of processing: United States

Personal Data processed: Trackers +1

Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on Whole In One Communion. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Whole In One Communion

Direct marketing via SMS

Company: Whole In One Communion

Personal Data processed: first name +2

Whole In One Communion uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Whole In One Communion.

Personal Data processed:
  • first name
  • last name
  • phone number
Service provided by:
  • Whole In One Communion
Meta Platforms Ireland Limited

WhatsApp Business direct marketing

Company: Meta Platforms Ireland Limited

Place of processing: Ireland

Personal Data processed: answers to questions +10

Whole In One Communion may send WhatsApp messages to the User for the purpose of direct marketing. Users may in most cases opt out of receiving direct marketing messages by tapping the opt out of marketing messages button in the chat.

Personal Data processed:
  • answers to questions
  • contents of the email or message
  • Data communicated while using the service
  • date of the message
  • first name
  • last name
  • phone number
  • profile picture
  • sender of the message
  • time the message was sent
  • user content
Service provided by:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Meta Platforms Ireland Limited

Meta Events Manager

Company: Meta Platforms Ireland Limited

Place of processing: Ireland

Personal Data processed: Trackers +1

Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Whole In One Communion.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Google Ireland Limited

Google Analytics 4

Company: Google Ireland Limited

Place of processing: Ireland

Personal Data processed: number of Users +3

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Whole In One Communion, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

Personal Data processed:
  • number of Users
  • session statistics
  • Trackers
  • Usage Data
Service provided by:

Connecting Data

This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.
This results in Data flowing through these services, potentially causing the retention of this Data.

Zapier, Inc.

Zapier

Company: Zapier, Inc.

Place of processing: United States

Personal Data processed: city +7

Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between (third-party) services.

Personal Data processed:
  • city
  • company name
  • country
  • email address
  • first name
  • last name
  • phone number
  • ZIP/Postal code
Service provided by:

Contacting the User

Whole In One Communion

Contact form

Company: Whole In One Communion

Personal Data processed: email address +3

By filling in the contact form with their Data, the User authorizes Whole In One Communion to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed:
  • email address
  • first name
  • last name
  • phone number
Service provided by:
  • Whole In One Communion
Whole In One Communion

Mailing list or newsletter

Company: Whole In One Communion

Personal Data processed: email address

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Whole In One Communion. Your email address might also be added to this list as a result of signing up to Whole In One Communion or after making a purchase.

Personal Data processed:
  • email address
Service provided by:
  • Whole In One Communion
Whole In One Communion

Phone contact

Company: Whole In One Communion

Personal Data processed: phone number

Users that provided their phone number might be contacted for commercial or promotional purposes related to Whole In One Communion, as well as for fulfilling support requests.

Personal Data processed:
  • phone number
Service provided by:
  • Whole In One Communion

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Whole In One Communion and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Inc.

Google Fonts

Company: Google Inc.

Place of processing: US

Personal Data processed: Trackers +1

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Whole In One Communion to incorporate content of this kind on its pages.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:

Handling payments

Payment processing services enable Whole In One Communion to process payments by credit card, bank transfer or other means. To ensure greater security, Whole In One Communion shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Apple Inc.

Apple Pay

Company: Apple Inc.

Place of processing: US

Personal Data processed: various types of Data as specified in the privacy policy of the service

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

Personal Data processed:
  • various types of Data as specified in the privacy policy of the service
Service provided by:
Whole In One Communion

Payment by bank transfer

Company: Whole In One Communion

Personal Data processed: company name +4

In the event that the chosen payment method is a direct bank transfer to the current account indicated by Whole In One Communion, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.

Personal Data processed:
  • company name
  • first name
  • last name
  • payment info
  • physical address
Service provided by:
  • Whole In One Communion

Seal Subscriptions

We collect customer's name, email address, shipping address, billing address.
For subscriptions with an active automatic charging functionality, we also collect the last four numbers of the payment card, expiration date of the payment card and the payment card type.
When customers browse the website, we might collect their network information, such as IP address, time of the visit and other network information for the purpose of providing the Service.

Google Ireland Limited

Google Pay

Company: Google Ireland Limited

Place of processing: Ireland

Personal Data processed: billing address +10

Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.

Personal Data processed:
  • billing address
  • email address
  • first name
  • last name
  • payment info
  • phone number
  • purchase history
  • shipping address
  • Trackers
  • Usage Data
  • various types of Data as specified in the privacy policy of the service
Service provided by:
 Shopify Commerce Singapore Pte. Ltd

Shop Pay

Company: Shopify Commerce Singapore Pte. Ltd

Place of processing: Singapore

Personal Data processed: billing address +11

Shop Pay is a payment management and product checkout page service provided by Shopify Commerce Singapore Pte. Ltd which allows Users to make online payments on Whole In One Communion.

Personal Data processed:
  • billing address
  • data relating to the point of sale
  • email address
  • financial information
  • first name
  • last name
  • payment info
  • phone number
  • privacy choices
  • product interaction
  • profile picture
  • purchase history
Service provided by:

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of Whole In One Communion, in order to contact and be contacted by Whole In One Communion‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Meta Platforms, Inc.

WhatsApp Business Chat widget

Company: Meta Platforms, Inc. +1

Place of processing: United States +1

Personal Data processed: answers to questions +10

WhatsApp Business Chat widget is a service for interacting with the WhatsApp instant messaging app and platform provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed:
  • answers to questions
  • contents of the email or message
  • Data communicated while using the service
  • date of the message
  • first name
  • last name
  • phone number
  • profile picture
  • sender of the message
  • time the message was sent
  • user content
Service provided by:
 Shopify Commerce Singapore Pte. Ltd

Shopify Chat

Company: Shopify Commerce Singapore Pte. Ltd

Place of processing: Singapore

Personal Data processed: billing address +19

Shopify Chat is a service for interacting with the Shopify live chat platform provided by Shopify Commerce Singapore Pte. Ltd.

Personal Data processed:
  • billing address
  • city
  • clicks
  • contents of the email or message
  • country
  • device information
  • email address
  • first name
  • geography/region
  • last name
  • order ID
  • phone number
  • product interaction
  • purchase history
  • shipping address
  • state
  • time zone
  • Trackers
  • Usage Data
  • User ID
Service provided by:

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Klaviyo Inc.

Klaviyo

Company: Klaviyo Inc.

Place of processing: United States

Personal Data processed: email address +3

Klaviyo is an email address management and message sending service provided by Klaviyo Inc.

To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

Personal Data processed:
  • email address
  • first name
  • last name
  • phone number
Service provided by:

Managing data collection and online surveys

This type of service allows Whole In One Communion to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Judge.me

Full name of legal entity: Judge.me Ltd
Company number: 12157706
Email address: support@judge.me
Postal address: c/o Buckworths, 1-3 Worship Street, London EC2A 2AB

Managing support and contact requests

This type of service allows Whole In One Communion to manage support and contact requests received via email or by other means, such as the contact form. The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Gorgias Inc

Gorgias is a comprehensive customer service platform designed specifically for e-commerce businesses, enabling them to enhance their customer support operations. It integrates various communication channels such as email, live chat, social media, and SMS into a single interface, allowing support teams to manage all customer interactions efficiently.

Platform services and hosting

These services have the purpose of hosting and running key components of Whole In One Communion, therefore allowing the provision of Whole In One Communion from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Shopify International Limited

Shopify

Company: Shopify International Limited

Place of processing: Ireland

Personal Data processed: billing address +9

Shopify is a platform provided by Shopify International Limited that allows the Owner to build, run and host an e-commerce website. This service may place Trackers on the User’s device. For the most up-to-date and comprehensive information, refer to the service’s official documentation.

Personal Data processed:
  • billing address
  • device information
  • email address
  • first name
  • last name
  • payment info
  • phone number
  • shipping address
  • Trackers
  • Usage Data
Service provided by:

Registration and authentication

By registering or authenticating, Users allow Whole In One Communion to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Whole In One Communion will be able to access some Data, stored by these third party services, for registration or identification purposes.

Google Inc.

Google OAuth

Company: Google Inc.

Place of processing: US

Personal Data processed: various types of Data as specified in the privacy policy of the service

Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.

Personal Data processed:
  • various types of Data as specified in the privacy policy of the service
Service provided by:

Registration and authentication provided directly by Whole In One Communion

By registering or authenticating, Users allow Whole In One Communion to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Whole In One Communion

Direct registration

Company: Whole In One Communion

Personal Data processed: billing address +4

The User registers by filling out the registration form and providing the Personal Data directly to Whole In One Communion.

Personal Data processed:
  • billing address
  • email address
  • first name
  • last name
  • phone number
Service provided by:
  • Whole In One Communion

Remarketing and behavioral targeting

This type of service allows Whole In One Communion and its partners to inform, optimize and serve advertising based on past use of Whole In One Communion by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Inc.

Remarketing with Google Analytics

Company: Google Inc.

Place of processing: US

Personal Data processed: Cookies +1

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

Personal Data processed:
  • Cookies
  • Usage Data
Service provided by:
Google Inc.

Google Ads Remarketing

Company: Google Inc.

Place of processing: US

Personal Data processed: Cookies +1

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Whole In One Communion with the Google Ads advertising network and the DoubleClick Cookie.

In order to understand Google's use of Data, consult Google's partner policy.

Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.

Personal Data processed:
  • Cookies
  • Usage Data
Service provided by:

SPAM protection

This type of service analyzes the traffic of Whole In One Communion, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google Inc.

Google reCAPTCHA

Company: Google Inc.

Place of processing: US

Personal Data processed: answers to questions +8

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

Personal Data processed:
  • answers to questions
  • clicks
  • keypress events
  • motion sensor events
  • mouse movements
  • scroll position
  • touch events
  • Trackers
  • Usage Data
Service provided by:

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on Whole In One Communion in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google LLC

Google Tag Manager

Company: Google LLC +1

Place of processing: United States +1

Personal Data processed: Usage Data

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

Personal Data processed:
  • Usage Data
Service provided by:

Traffic optimization and distribution

This type of service allows Whole In One Communion to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Whole In One Communion and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare

Cloudflare

Company: Cloudflare

Place of processing: US

Personal Data processed: Cookies +1

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through Whole In One Communion, i.e., communication between Whole In One Communion and the User's browser, while also allowing analytical data from Whole In One Communion to be collected.

Personal Data processed:
  • Cookies
  • various types of Data as specified in the privacy policy of the service
Service provided by:

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Whole In One Communion, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Whole In One Communion.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Whole In One Communion.

Klaviyo Inc.

Klaviyo CRM

Company: Klaviyo Inc.

Place of processing: United States

Personal Data processed: city +12

Klaviyo CRM is a User database management service provided by Klaviyo Inc.

Klaviyo CRM can also be used as a medium for communications, either through email, or through messages within Whole In One Communion.

To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

Personal Data processed:
  • city
  • company name
  • country
  • email address
  • first name
  • last name
  • phone number
  • physical address
  • purchase history
  • state
  • Trackers
  • Usage Data
  • various types of Data
Service provided by:

Further information about the processing of Personal Data

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Whole In One Communion depends on the payment system used.

Further Information for Users in the European Union

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Whole In One Communion or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Whole In One Communion may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Whole In One Communion and any third-party services may collect files that record interaction with Whole In One Communion (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Whole In One Communion and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.