DRINKCOACH PRIVACY POLICY

 

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site [https://www.drinkcoach.org.uk], including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 18 years of age.

Waythrough is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

[We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details
Our full details are:

Full name of legal entity: Waythrough
Name of Data Protection Officer: Hope and May
Email address: dpo@waythrough.org.uk
Postal address: Waythrough, Inspiration House, Unit 22 Bowburn North Industrial Estate. DH6 5PF.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at innovation@waythrough.org.uk.

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, last name, username, date of birth and gender.

  • Contact Data may include your billing address, delivery address, email address, online video call name, and telephone numbers.

  • Financial Data may include your bank account and payment card details.

  • Transaction Data may include details about payments between us and other details of purchases made by you.

  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

  • Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.

  • Usage Data may include information about how you use our website, products and services.

  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Special Category Data

We need to collect the following special category data about you in order to deliver the services/product:

  • Ethnicity data as part of assessment.

  • Health data related to alcohol consumption including number of drinking days, units consumed, psychological rating, physical health rating, overall wellbeing rating and Alcohol Use Disorders Identification Test (AUDIT) score as part of assessment and evaluation.

We require your explicit consent for processing special category data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

  • order our products or services;

  • create an account on our site;

  • subscribe to our service or publications;

  • request resources or marketing be sent to you;

  • enter a competition, prize draw, promotion or survey; or

  • give us feedback.

Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • Analytics providers such as Google based outside the EU; and

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [PayPal] based inside the EU and [BookingLive] based inside the EU. and

  • We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

4. HOW WE USE YOUR PERSONAL DATA

We will only process your personal data when we have an appropriate lawful basis. The most common uses of your personal data are:

  • Where we need to perform the contract between us.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a lawful basis for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at innovation@waythrough.org.uk or by following the opt-out links on any marketing message sent to you.

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the lawful basis on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please email us at innovation@waythrough.org.uk if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the below.

  • To register you as a new customer of the Online Coaching Service we will collect Identity and Contact data for the lawful basis of performing a contract with you.

  • To process and deliver your booking including:
    (a) Manage payments, fees and charges and
    (b) Collect and recover money owed to us; we will collect Identity, Contact, Financial, Transaction and Marketing and Communications data for the lawful basis of performing a contract with you and a necessary function for our legitimate interests to recover debts owed to us.

  • To manage our relationship with you which will include:
    (a) Notifying you about changes to our terms or privacy notice and
    (b) Asking you to leave a review or take a survey at the end of your agreed number of sessions we will collect Identity, Contact, Profile and Marketing and Communications data for the lawful basis of

(i) Performing a contract with you,
(ii) Necessary to comply with a legal obligation and
(iii) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.

  • To enable you to partake in a prize draw, competition or complete a survey we will collect Identity, Contact, Profile, Usage and Marketing and Communications data for the basis of
    (a) Performing a contract with you and
    (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

  • To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) we will collect Identity, Contact, and Technical data for the lawful basis of
    (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise and
    (b) Necessary to comply with a legal obligation.

  • To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising we will collect Identity, Contact, Profile, Usage, Marketing and Communications, and Technical data for the lawful basis of  legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.

  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences we will collect Identity, Contact, Technical, Usage and Profile data for the lawful basis of  legitimate interests to develop our products/services and grow our business.

  • To make suggestions and recommendations to you about goods or services that may be of interest to you, we collect Identity, Contact, Technical, Usage and Profile data for the lawful basis of legitimate interests to develop our products/services and grow our business

Marketing communications

You will receive marketing communications from us if you have:

(i) requested information from us or purchased goods or services from us; or

(ii) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and

(iii) in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at innovation@waythrough.org.uk at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at innovation@waythrough.org.uk.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the appropriate lawful basis.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where personal data is stored outside of the UK and the EEA, safeguards to protect personal data may include but are not limited to the UK Addendum used in conjunction with the EU Standard Contractual Clauses (SCCs), or UK International Data Transfer Agreement (IDTAs). Such safeguards will be subject to Transfer Risk Assessments (TRAs). 

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 such data. 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.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

For more information on our retention policy, please contact us on innovation@waythrough.org.uk.

9. YOUR LEGAL RIGHTS

You have the following rights: 

  • ‘Right to be informed’, which means we will be completely clear and transparent about how we plan to use your personal information. 

  • ‘Right of access’, which means you can request details of the personal information we hold about you and how we use it. We will provide this within one month. 

  • ‘Right to rectification’, which means you can ask us to update or amend the personal information we hold about you, if it is incorrect. 

  • ‘Right to restrict processing’, which means you can ask us to change, restrict or stop the way we are using your personal information. 

  • ‘Right to erasure’ (or ‘right to be forgotten’), which means you can ask us to remove your personal information from our records. 

  • ‘Right to object’, which means you can object to us using your personal information for marketing purposes. 

  • ‘Right to data portability’, which means you can obtain the personal information we hold about you and reuse it for your own purposes. 

  • ‘Right not to be subject to automated decision making’, which means if we use systems to make a decision about you, you have the right to ask for a person to intervene, which may change the outcome. 

  • Right to lodge a complaint with a supervisory authority, such as the Fundraising Regulator or the Information Commissioner’s Office (ICO), if you are not satisfied with our response to a request you make to us, or you feel we are not using your information correctly. 

If you wish to exercise any of the rights set out above, please email us at innovation@waythrough.org.uk.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

12. CoachBot

The coachbot is a chatbot feature designed by DrinkCoach and Virtual Health Labs. We do not collect any personally identifiable information when you use the coachbot. It has been designed to be anonymous so you can feel confident to use the feature.  

Your responses to the chatbot are stored in a way that does not identify any individual's personal data. We will not collect IP addresses or chat names entered. 

Responses are used to make improvements to the chatbot.  

Storage is maintained on secure Google cloud servers by our partners Virtual Health Labs Ltd. The Google servers are based in the EEU and data is not transferred outside of the EEU. 

The data is kept in ISO27001-certified data centres with no transfer outside the EU.  

This data will not be shared or sold. 

Further enquiries contact: info@virtualhealthlabs.org or innovation@waythrough.org.uk

13. Parents and Alcohol Pages 

The parent and alcohol interactive tools. 

Last updated: 29th September 2025