Delvvy™ LTD (“we”, “us”, or “our”) respects the trust you place in us when you share personal data. We believe trust is the foundation of intimacy and are committed to being open and honest about our use of personal data, including special category data.

The purpose of this policy is to provide our data subjects (“you” or “your”) with transparent information on our use of personal data.

This Privacy Policy applies to our website and services. It includes all personal data we process automatically and manually through direct communication and third-party data processors.

You are advised to read this policy carefully. Please do not use our website or engage in our services if you do not accept these terms.

Company
Delvvy™ LTD provides education, coaching, and consultancy services to individuals and organizations about sexual and reproductive health and justice. We are registered as a limited company in England and Wales, registration number 15760294.

Data Protection
Delvvy™ LTD recognises and respects its data protection obligations, including but not limited to the EU General Data Protection Regulation, the UK General Data Protection Regulation, and the Data Protection Act 2018. We are a Data Controller and are registered with the Information Commissioner’s Office, registration number ZB802272.

Contact
Our registered office address is 85 Great Portland Street, London, England, W1W 7LT. Our email address is hello@delvvy.com.

Data subjects are identified or identifiable living individuals to whom personal data relates. Data subjects have the right to access their personal data, request rectification, object to processing, and have their personal data erased.

Our data subjects are individuals and organizations who use our website, buy our products, and/or engage with our services.

Rights of Our Data Subjects

Our data subjects have the following rights to their personal data:

Right to access: the right to request the information we hold.
Right to correct: the right to rectify Data if it is inaccurate or incomplete.
Right to erase: the right to request that we delete or remove Data from our systems.
Right to object: the right to object to our use of Data.

Underage Data Subjects

The GDPR outlines that it is lawful to process personal data when offering information society services to people 16 years and older.

While we believe in the need for comprehensive sex education across all stages of life, we do not market our website or offer our services to those under the age of 16. Consistent with the GDPR, we will never knowingly request personally identifiable information from anyone under the age of 16. We require all our data subjects to declare they are over the age of the 18, as outlined in our Terms of Service.

GDPR defines personal data as any information associated with an individual who can be identified directly or indirectly. This term does not apply to data that has been anonymised, where personal identity has been removed.

Personal data encompasses a variety of categories, including:

Identity: Title, name, date of birth.
Profile: Website username, password, and preferences.
Contact: Billing address, email address, telephone numbers.
Financial: Card payment information, bank account details.
Service: Details of services or products purchased.
Technology: IP address, Cookies data.

We may collect personal data for the purpose of providing sexual and reproductive health and justice services and products. We will always require a statement of consent when providing services or products that may result in processing personal data.

Our personal data collection includes but is not limited to:

Browsing our website.
- Cookies data
Creating an account on our website
- Name.
- Email address.
- Email preferences.
Registering for a service on our website.
- Name.
- Email address.
- Email preferences.
- Record of services purchased.
Paying for a service or product on our website.
- Payment information.
- Billing Address.
- Record of services purchased.
- Record of products purchased.
Online communication with us.
- Name.
- Email address.
- Email preferences.
- Additional personal data that the data user believes is necessary to share when inquiring about our services.

We use trusted data processors to collect, process, and store personal data. Each processing partner is listed here with a description of our use and a link to their privacy policy.

Squarespace
- Purpose: Website hosting platform that we use to book services , sell products, and process payments.
- Privacy Policy: Read here.
Zoom
- Purpose: Video conference service that we use for meetings and to provide online services.
- Privacy Policy: Read here.
Google
- Purpose: Productivity software that we use for business operations, including email, calendar, cloud-based storage, documents, and analytics.
- Privacy Policy: Read here.
Xero
- Purpose: Accounting software that we use for business operations, including accounting, bookkeeping, payroll, and payments.
- Privacy Policy: Read here.
Monzo
- Purpose: Online bank that we use for banking operations.
- Privacy Policy: Read here.
Stripe
- Purpose: Payment processing service that we use to process payments.
- Privacy Policy: Read here.
Paypal
- Purpose: Payment processing service that we use to process payments.
- Privacy Policy: Read here.
GoCardless
- Purpose: Payment processing service that we use to process payments.
- Privacy Policy: Read here.
WhatsApp
- Purpose: Social media platform that we use for online communication.
- Privacy Policy: Read here.
LinkedIn
- Purpose: Social media platform that we use for online communication and content creation.
- Privacy Policy: Read here.
Instagram
- Purpose: Social media platform that we use for online communication and content creation.
- Privacy Policy: Read here.

The UK GDPR singles out a subset of personal data, known as special category data, which is considered more sensitive and requires extra protection under privacy regulations. Companies need a valid legal basis for processing this data and explicit consent from the individual. These protections are in place to protect an individual’s fundamental rights and freedom.

Special category data includes:

personal data revealing racial or ethnic origin;
personal data revealing political opinions;
personal data revealing religious or philosophical beliefs;
personal data revealing trade union membership;
genetic data;
biometric data (where used for identification purposes);
data concerning health;
data concerning a person’s sex life
data concerning a person’s sexual orientation.

What is explicit consent?
All consent must involve a specific, informed and unambiguous indication of the individual’s wishes. Data subjects can consent to use personal data through a written or verbal statement or by clear affirmative action.

However, the processing of special category data requires explicit consent. Explicit consent must be expressly confirmed in words, written or verbal, and cannot be obtained through affirmative action. It requires individuals to clearly understand what they consent to and can easily indicate their agreement, for example, by signing a document or ticking a box.

We may collect special category data for the purpose of providing sexual and reproductive health and justice services. We will always require explicit consent when providing services that may result in processing special category data.

We will only request special category data when it is relevant and necessary to the service provided. We will only maintain records of special category data when it is essential to facilitate ongoing services. We will never request special category data through automatic means (booking or inquiry form).

Special category data we may collect that are relevant to our services include:

personal data revealing racial or ethnic origin;
personal data revealing political opinions;
personal data revealing religious or philosophical beliefs;
data concerning health;
data concerning a person’s sex life
data concerning a person’s sexual orientation.

We will only ever request special category data when you are engaging in coaching services. We will collect this data through verbal conversations and will ever take notes of the information when it is necessary for providing continuing services. We use a trusted a data processor to store special category data. Our processing partner is listed here with a description of our use and a link to their privacy policy.

Zanda Health
- Purpose: CRM platform that we use to store coaching client records.
- Privacy Policy: Read here.

In compliance with the GDPR, we will report any unlawful data breach within 72 hours if we determine that personal data under our control has been compromised or potentially compromised. In the event of a 'high risk' breach, we will inform all affected data subjects through an appropriate communication method. Relevant breaches will also be reported to the Information Commissioner's Office.

We reserve the right to change this Privacy Policy at any time. We will inform our data users if we update this policy and will require consent for the continued use of our services when the policy is updated.

If you disagree with the modified policy, please stop using our website and services.

We will always require a written statement of consent when providing services or products that may result in processing personal data and special category data.

All individuals and organizations who book our services or purchase our products must agree to our Privacy Policy and Terms of Service.

If engaging in an interactive community orientated service, such as workshops or events, all participants must sign a confidentiality statement upon registration. If engaging with our coaching services, all clients must sign a client agreement and provide explicit consent for the processing of special category data.

As our data users, you have the right to withdraw your consent at any time. If you no longer wish for us to process your personal data or special category data, please contact us and we will delete all of your data we have on record.

If you do not agree to the terms outlined in this policy, please do not engage with our website, services, or products.

If you have any questions about this policy, you can contact us via email:

hello@delvvy.com