REFINE WITH ALFI APP

PRIVACY & COOKIE POLICY

Navl Limited provides an avatar-led multi-discipline mobile fitness instructor App that helps you improve your fitness with a customisable avatar.  

By visiting and continuing to browse our websites at the domain www.refinewithalfi.com  (and any other websites under our control), you are deemed to have accepted the following terms which form our Privacy & Cookie Policy.

If you intend to use our services, you should also refer to our End User Agreement.

Whether you browse as a guest or use our services, we may collect different types of information about you for various purposes, which can include:

• improving for website functionality; 

• providing improved or personalised services to you; 

• helping us decide what kind of information users will see on the site; and, 

• in accordance with your chosen preferences, to market our services to you. 

We are not responsible for the content or privacy practices of external sites, third party apps or your chosen internet browser. However, we do seek to explain how we work with third parties, including search engines and ad servers such as Google. You can see Google’s Privacy Policy here.

This Privacy and Cookie Policy explains how we, including our staff, use any of your personal information we collect and how you can limit our use of it.

1. Interpretation

In this Policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;

• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses,

• schedules or appendices of this privacy policy;

• a reference to a person includes firms, companies, government entities, trusts and partnerships;

• “including” is understood to mean “including without limitation”;

• reference to any statutory provision includes any modification or amendment of it;

• the headings and sub-headings do not form part of this privacy policy.

2. Scope of this Policy

This Policy applies only to the actions of Navl Limited and users with respect to our websites. It does not extend to any websites that can be accessed from our websites, including, but not limited to, any links we may provide to social media websites.

For purposes of any applicable data protection laws, Navl Limited is the “data controller”. This means that Navl Limited determines the purposes for which, and the manner in which, your data is processed.

3. The information we gather

The information that we may gather falls broadly into two types:-

3.1 Information that relates directly to you (e.g. your name and contact details, debit or credit card details or bank account details, your requirements as a customer (which may include information about others known to you or who have dealings with you), communication preferences and customer history).

3.2 Information that does not directly identify you (e.g. how you might browse our website), specifically:

• your IP address through the placement of cookies; and,

• location data, which might be gained through your IP address or GPS data.

Please note that not all cookies are either personally identifiable information or even unique identifiers; but some can be, while others can influence what you see on our website and others.

4. How we use your information

Often, we will be using your information in accordance with your specific consent or instructions: for example, because you have requested or consented to receiving certain information or entered into a contract with us for our services.

At other times we will use your information for one of the other lawful purposes described below.

Provision of services

When you enter into a contract for our services, or where you wish to register an interest in doing so, we will use your personal data to enter into and fulfil our contractual relationship with you.

Fulfilling our contract with you means being able to manage and administer our services, and maintain our standards of tailored service levels, customer care and consumer compliance. This may include, among other things, fulfilling orders or returns, processing payments or refunds, and providing aftercare.

We may disclose your debit/credit card or banking information to appropriate third parties during payment processing for the purposes of fraud prevention.

Other uses of your information

Other uses of your information are made for purposes which we think are necessary for our legitimate interests as a service provider, including to promote our services to you in the future, and to recognise and remember you when you visit our website and better understand how you use our website and others by using cookies to follow your use.

We may (without implying any obligation):

• put your information in aggregated form into groupings (known as “segments”) by a particular audience, which means we can serve you advertisements and offers that will interest you within the website, including by reference to data we receive from third parties;

• keep you updated on any services you have subscribed to and/or about similar services unless you have told us otherwise;

• contact you to let you know about any of our services, competitions or promotions (which may in some cases be provided by third parties), including by email, mail, telephone, or SMS text message, always having regard to your preferences;

• make sure materials on the website or in apps are presented in the most effective way for you and your computer or mobile device; and,

• collect and log numeric internet addresses to improve the website and to monitor website usage.

Some limited uses of your data are also required to comply with legal obligations, for example co-operation with the police and other authorities for the purposes of law enforcement.

5. How we gather information

Information is gathered in the following ways:

• indirectly (e.g. using website technology that tracks and administers your visits through your browser, or similar technology) on a mobile device, or when you log on and/or share stories through social media;

• directly (e.g. when you complete our online enquiry form or online chat facility or we ask you to complete a customer review to be published on our site and social media);

• through your device (e.g. mobile, PC or tablet) where you have enabled location services. This may be used for location targeted services or advertising in accordance with your preferences, which may be adjusted either on your device or via server, App or website preferences;

• through location technology for mobile web services. The service we use is based on machine learning algorithms which analyse data from different connection types. These include fixed http and https connections, location consent requests on https sites and from mobiles Apps using https connections; and,

• through social media sign-on, if we decide to offer this. If you decide to contact us this way, you are granting permission to that social media company to share your user details with us, and to collect information about you and how you use our site (which process we do not control and will be subject to the terms and conditions of your social media account).

6. How do you decide how you want to hear from us?

• We will try to contact you in accordance with your preferences, including by email, phone, post and SMS text, but we reserve the right to specify a particular mode of contact.  We always seek to explain why and how we might contact you at the point you give your information to us.

• We also provide the means for you to grant or withhold your permission for us to contact you. We do this by using opt-in boxes or unsubscribe options.

• Sometimes, we need your information to be able to contact you to provide the 

service you wish to use. In those cases, by signing up to the service you are 

agreeing that we will have to send you service communications to run the service itself, and we will not offer you the chance to opt-out from receiving those messages until either the contract has been performed or (where there is no current contract between us for the provision of a service), you decide you no longer wish to use the services.

7. Accessing and updating your personal information

You can update your details and marketing preferences or receive a copy of all information we hold on you by emailing us at: info@refinewithalfi.com or by writing to us at Refine with ALFI, 14 Collent Street, Hackney, London, E9 6SG.

8. Cookies and similar technologies

A cookie is a small piece of information that is placed on your computer when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes, such as tags and identifiers. 

When you first visit our site(s) using a new browser, or if you visit in private browsing mode, we may provide you with a cookies permission banner seeking your consent to use of cookies as required by law. From this banner you will be able to access our cookies management tool. By clicking ‘OK’ or clicking through to any part of the site, we will start to manage your visit using cookies.

We may from time-to-time use the following types of cookie, as will your browser:

Please note that we have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies, including your browser (such as Google), data management providers and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.

9. Managing your cookies preferences

• Most browsers allow you to turn off cookies. To do this look at the “Help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates. We may also provide our own cookie management tool for you to make more specific choices about how cookies are used for your visits to our site.

• We may also use third party cookies, as will your browser. These are cookies that may be read by third parties (for example, if you have used social sign-on and have the option to like or comment using your social media account).

• We use various third parties to provide us with information to help us learn about how users use our website. 

If you would like to disable “third party” cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party’s website and getting them to generate a one-time “no thanks” cookie that will stop any further cookies being written to your device. 

Please note that even after disabling this, you may still see “non-personalised” advertisements that may appear materially the same as the “personalised” ones. This is simply a function of what advertisers and partners we are working with, and does not mean your preferences have not been applied.

Please note also that the likes of Google will still use cookies for necessary administrative purposes after you have amended your personalised advertising settings. These purposes include frequency capping (namely to stop users being served the same advertisements repeated), aggregated reporting of engagement (on a non-personal basis) and to combat fraud and abuse (for example, to prevent bogus click-throughs by web hosts to inflate the value of their platform).

10. Protecting your information

We invest in high-quality security and do our utmost to protect user privacy. No data transmission over the Internet can be entirely secure, and therefore we cannot guarantee the security of your personal information and/or use of the website. Any information that you send is at your own risk and may be read by others. However, once we have received your personal information we use strict procedures to protect the security of your personal information.

11. Disclosing your information

• Selling our businesses

We may disclose your personal information to third parties and their advisers if we are approached by a potential buyer in connection with the potential sale of our business or of any part of it. Should we proceed to sell or reconstitute any part of our business that holds your personal information, it will be necessary in some circumstances to share or transfer that information to the buyer or new entity: for example, so that they can continue to provide continuity of service to you. You will always be notified of such a change of control or ownership, and will be given the opportunity to object or opt out of any further communications from us or the buyer or new entity, except where such use of your personal information is necessary for a lawful purpose (such as a legal obligation or right, or where necessary to perform an existing contract with you)

• Your internet browser or other accounts

Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalised advertising that it provides to us and other sites. If you use social media sign-on (such as with Facebook), you will be enabling sharing of information between us and that site.

• Our partners, agents and professional advisers

We never sell personal information, or pass it to third parties for their own marketing purposes, without your permission. We sometimes provide your personal information to third parties who are our subcontractors or providers of various products and services on our behalf and intermediaries, in order to fulfil orders. Your personal information will always be subject to appropriate protections under contract. 

• Legal requirements

We may disclose your personal information if we are required to do so by law, or if in good faith we believe such action is necessary to comply with the law a legal obligation.

• Data processors 

In common with most organisations, some of our functions using your personal information are outsourced to contractors. Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.

Where we store your personal information

The personal information that we collect from you will sometimes be sent and stored outside the European Economic Area (“EEA”) in order to carry out the activities listed in section 2 above (‘How we use your information’). Except where this is on your specific instructions, this will always be subject to adequate safeguards as to the protection and security of your personal data. Further details are available on enquiry from info@refinewithalfi.com.  

We will only keep your personal information for as long as we need it for a lawful purpose: whether because of the services we have provided to you (and to allow for reasonable retention of records afterwards to reflect legal requirements or limitation periods),or because we believe you still wish to hear from us.

12. A summary of your rights

You have the following rights:

• to obtain access to, and copies of, the personal data that we hold about you, or require that it is transmitted to another data controller;

• to request that we restrict our data processing activities or cease processing your personal data in certain ways, for example because you do not consider it lawful;

• to require us not to send you marketing communications;

• to withdraw your consent, where we are relying on it to process your personal data;

• to object to how we process your personal data, in particular where we are relying on our legitimate interests; and,

• to ask us to erase the personal data we hold about you, for example because it is causing you distress or you believe it to be no longer relevant, or to correct the information if it is incorrect.

If you would like to exercise any of your rights as stated above, you can do so by emailing us at info@refinewithalfi.com.

Please note that the above rights are not absolute, and we will be entitled to refuse requests where exceptions apply.

13. General

• You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

• If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected. 

• Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

• This Agreement will be governed by and interpreted according to English law. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the courts of England & Wales. 

14. Changes to this Policy

If we change our Policy, we will post the changes on this page. Please check the website regularly for any changes to this Policy. Any significant changes will be provided to you directly where possible.

You are deemed to have accepted the terms of the Policy on your first use of the website following the alterations.

If you don’t feel we’re adhering to this Policy…

If you believe that we have not adhered to this Policy, please notify us by email at info@refinewithalfi.com and we will try to solve the problem promptly. If you are not satisfied with our response, or have any other queries, you can also contact the Information Commissioner at the following address:

Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire,

SK9 5AF.

This Policy was last updated on 22^nd September 2020.