9th November 2020


Name:                                         Winter Wellness is a trading name for Form Movement Ltd (“Form”, “we”, “us”, or “our”). 

Registered Address:              71-75 Shelton Street, London, WC2H 9JQ

Phone Number:                      +44 7595 459030


Email:                                         [email protected]


We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at [email protected].today.


When you visit our website,  (“the Site”) and use our services, you trust us with your personal information. We take your privacy very seriously. In this document, we describe our Privacy Policy. We seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue the use of our Site. By continuing to use our site you expressly accept the terms of this Privacy Policy.


This Privacy Policy applies to all information collected through the website, and/or any related services, sales, marketing, or events regarding the Winter Wellness Plan (we refer to them collectively in this privacy policy as the "Sites"). 


Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  


We respect your right to privacy and will only process personal information about OR provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 and other applicable privacy laws.



The personal information you disclose to us 

The personal information that we collect depends on the choices you make and the plan you subscribe to. The personal information we collect may include the following:


  • Your name, address, and email address
  • Whether you are unemployed, an NHS worker, or currently furloughed
  • Your business name, address, and contact email
  • Comments that you make on our Site or feedback that you provide to us which are identifiable to you


Information automatically collected 

We automatically collect certain information when you visit, use, or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include usage information and information about how and when you use our Sites and other technical information. This information is needed to maintain the security and operation of our Site, for our internal analytics, Aggregated and Anonymised reporting purposes and to improve our service to you.

Aggregated and Anonymised Data

We may collect and use Aggregated and Anonymised data for reporting such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. In the event that we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.



We process the personal information we collect or receive for the following purposes: for our business purposes (“Legitimate Business Interests”), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.  


Legitimate Business Interests


To send administrative information to you

We may use your personal information to send you product and service information and/or information about changes to our terms, conditions, and policies


Request feedback

We may use your information to request feedback and to contact you about your use of our Site


To protect our Site

We may use your information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring and prevention)


For other business purposes

We may use your information for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Site products, services, marketing, and your experience


To deliver on our contractual obligations to you



To enforce our terms, conditions, and policies



To send information to you

We may use your personal information to send you new product, and service information, marketing, and information on our related business’


To respond to legal requests and to prevent harm

If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond






We are allowed to disclose your information in the following cases:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. 
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable laws, governmental requests, a judicial proceeding, court order, or legal process. 
  • Vital Interests: We can exchange information with others to protect against fraud or credit risks.


More specifically, we may need to process your data or share your personal information in the following situations:   

  • Other Third-Party Service Providers. We may share your data with third-party service providers who perform services for us or on our behalf. Examples include Site delivery & operation, customer service, and marketing efforts. We do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. 
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.        



We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.  

  • To communicate and provide you with information about our services
  • Site functionality and to on our contractual obligations you who’s Privacy Policy can be found here
  • User account registration
  • Data storage




This Site is intended for users aged 18 and over and we do not knowingly collect data relating to such children.



Cookies are small text files we may place on your device when you visit our site and are used to make the users experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of the Site however, for non-essential cookies we need your permission. All Cookies used by and on our website are used in accordance with current English and EU Cookie Law. We may use cookies to distinguish users and improve our Site.



We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than the period of time in which users have an account with us.


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.



Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures 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.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship has ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.


When you submit information via our Site, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us or deleting your account, which you may do by unsubscribing using the contact provided above in this Privacy Policy).


Under the GDPR, you have the right to:

- request access to, deletion of, or correction of, your personal data held by us at no cost to you;

- request that your personal data be transferred to another person (data portability);

- be informed of what data processing is taking place;

- restrict processing;

- to object to the processing of your personal data; and

- complain to a supervisory authority.


You also have rights with respect to automated decision-making and profiling as set out below.


You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

To enforce any of the foregoing rights or if you have any other questions about our Site or this Privacy Policy, please contact us at [email protected].


Please note that our terms and conditions and our policies only apply to and will not apply to other websites that you get to via a link from our Site. We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.



Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.



We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. 




The GDPR requires us to appoint a Data Protection Officer (DPO).  If you have questions or comments about this policy, you may contact our DPO by email at [email protected] or by post to:

Form Movement Ltd  

71-75 Shelton Street



United Kingdom