Privacy Policy

Last updated: September 12, 2024

Who we are

We at Daha Ventures Limited (company number 652098) (“Daha”, “we”, “us” or “our”) respect your privacy.

This Privacy Policy describes how we collect, use and share your personal information and applies to:

those who explore our digital experience and domains, including dahawellness.com (our “Digital Experience”) (“Visitors”);
clients who visit our Wellness Centre and who purchase and avail of our products and services (the “Services”) (“Clients”); and
members who sign up for a Daha Wellness account(“Members”).

Visitors, Clients and Members are together referred to throughout this Privacy Policy as “you” and “your”.

This Privacy Policy does not apply to the practices of third parties who you may choose to share information with when you use our Services. Please note that the collection and use of your information by these third parties is subject to their own privacy policies and terms. You should understand the privacy and security practices of any third party before you share information with them.

What information we collect

Information Category	Description of Information Collected
Information You Provide We process certain information that you provide directly to us.
Basic Client Information We collect certain information from you when you visit our Wellness Centre or avail of our Services.	Your full nameYour contact information, including your email address, postal address and phone numberYour genderYour date of birthRecords of the Services that you have purchased from us
Payment Information We collect certain payment information when you purchase our Services.	Your bank account details, credit card details or other payment details
Wellness History We collect information about your wellness history relevant to the Services that you have purchased. For example, if you are booked for a massage, we will ask about any prior injuries or circulation issues.	Your recent injuries, accidents or operations Any chronic illnesses you may suffer fromAny allergies or sensitivities relevant to your treatment
Wellness Preferences During the course of a treatment or afterwards, we may collect and store your preferences to improve your future visits.	Your treatment preferences, e.g. scents, sounds, etc.Your preferred therapistAny other preferences you may communicate to us
Oura Ring Information Where you choose to link your Oura Ring with Daha Wellness, we can access your Oura Ring information such as your sleep patterns, readiness and movement.	Your sleep patternsYour heart rate patternsYour activity historyYour resilience
Support Information We collect certain information when you engage with our Admin Team for help and support.	Your communications with our Admin Team
Survey Responses and Market Research You may choose to provide certain information in connection with surveys, research and other feedback mechanisms.	Your feedback on our ServicesAny additional information you may provide
Information We Collect Automatically Daha automatically receives and records information from your browser or your mobile device when you visit our Digital Experience or use certain features of the Services.
Browser and/or Device Information Daha automatically receives and records information from your browser or your mobile device when you visit our Digital Experience.	IP addressBrowser informationDevice type Operating system information
Service Usage Information	Usage Information: information about your interaction with our Digital Experience, including the date and time you accessed our Digital Experience, and other actions you take (such as clicking on particular parts of the Digital Experience).Diagnostic and Troubleshooting Information: Information about how our Digital Experience is performing, including timestamps, crash data, webDigital Experience performance logs and error messages
Cookie Information We collect certain information about you through cookies.	For more information about these online tools and how we use them, see our Cookies Policy.
Information We Receive from Third Parties We receive certain information about you from third parties
Information from our Analytics Partners We receive certain information about how you interact with our Digital Experience, marketing materials and social media	Your browsing history on our site
Information from our Diagnostic Partners We receive certain information about you from our Diagnostic Partners where you elect for our Diagnostic Services (e.g. Gut Biome Analysis)	The results of your Diagnostic Tests

How we use your information and our legal basis

We collect, use, share, and otherwise process your personal information for the purposes described in this Policy. To the extent required by applicable law, we rely on a number of legal bases to use your information in these ways.

The legal basis upon which we process your personal data will depend on the nature of your relationship with us.

Why and How We Use Your Information	Information Categories Used
Where necessary to perform our contract with you We use certain information that is necessary for us to provide you with the Services or to enter into a relevant contract (including an employment contract) with you.
To provide our Services We use certain personal information in order to provide you with our Services.	Basic Client InformationPayment InformationWellness PreferencesInformation from our Diagnostic Partners
To create a Member Account You can sign up for a Daha Wellness Membership for discounts and other benefits.	Basic Client InformationPayment Information
To provide Admin Support We need to process certain information in order to address your request for support.	Basic Client Information Support InformationDiagnostic and Troubleshooting information
To send Service communications We use certain information to send you administrative communications about our Services. You may not opt-out of receiving service communications.	Basic Client Information
To provide our Newsletter You can sign up for our Newsletter to learn about wellness trends and advice.	Email Address
Where necessary to comply with our legal obligations Our Services are subject to laws and regulations that require us to collect, use, and store your personal information in certain ways.
To comply with legal and regulatory obligations Daha may also use, preserve, or release your personal information to a third party to comply with our legal and regulatory obligations, including in response to lawful requests by public authorities (including tax authorities) and to meet legitimate national security or law enforcement requirements. Examples of laws that may require us to collect, use or disclose your information: Civil, commercial, criminal, or consumer protection matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings or regulatory inquiries (e.g. orders or mandatory requests under the Irish Competition and Consumer Protection Act 2014, the Consumer Rights Act 2022, or the Liability For Defective Products Act, 1991). Corporate and taxation matters: to complywith our corporation and taxation obligations, such asthose under the Irish Companies Act 2014 and the Taxes Consolidation Act 1997. Regulatory matters: to comply with our regulatory obligations, including engaging with our regulators, such as (but not limited to) the Data Protection Commission.	Basic Client Information Payment InformationBrowser and Device InformationService Usage Information
Where necessary for our legitimate interests We rely on our legitimate interests or those of third parties where they are not outweighed by your rights and freedoms.
Why and How We Use Your Information	Legitimate Interest Relied On		Information Categories Used
To understand how you use our Digital Experience and Services and improve your experience We use certain information to improve our Services, understand how you interact with the Digital Experience and Services and enable accurate and reliable reporting.	It is in our legitimate interests to understand how our Services are being used, and to explore and unlock ways to develop and grow our business. It is in our legitimate interests, and those of our Visitors, Clients and Members, to improve the efficiency of our Services, troubleshoot errors with our Services and obtain insights into usage patterns of our Services.		Service Usage Information Browser and Device Information Cookie Information
To promote our Services We use certain information about you to promote our Services.	It is in our interest to promote our Services and engage with the community.		Basic Client Information
To protect our legal rights Daha may also retain, preserve, or review your personal information to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims.	It is in our interest to protect and defend ourselves from legal claims.		Basic Client InformationPayment Information
To research and innovate We carry out surveys of your experience using the Services.	It is in our interest and our Clients’ and Members’ interests to improve our offerings through information obtained from these research surveys.		Basic Client Information Survey Responses and Market Research
In the event of a business reorganisation In some cases, Daha may choose to reorganise its business. In these types of transactions (such as a sale, merger, liquidation, receivership, reorganisation, or transfer of all or substantially all of Daha’s assets).	Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term.		Basic Client Information
Where you provide your consent When we use your information based on your consent, you have the right to withdraw your consent at any time on a go-forward basis (meaning our prior use of your data will it be affected)
To adjust your treatment based on your Wellness History We rely on your consent to process certain health information in order to adjust your treatment accordingly.		Wellness History
To send you email and SMS marketing We rely on your consent to send you email and SMS marketing messages. You can unsubscribe from these messages at any time.		Basic Client Information

Who do we share your data with?

We share your data with third parties where necessary to perform the Services, comply with our legal obligations, or for purposes set out in this Privacy Policy, including:

Linked Third Party Websites: When you use third-party services or websites that are linked through our Services, the providers of those services or products may receive information about you that we, you, or others share with them. Please note that when you use third-party services which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.

Professional Advisors, Industry Partners, Authorities and Regulators: We share your information described above under section ‘How We Use Your Information and Our Legal Basis’ with our advisors and consultants, regulators and tax authorities, law enforcement, government agencies, civil litigants, and industry partners to:

comply with applicable law or regulations, court orders, subpoenas, legal process or government requests;
detect, investigate, prevent, or address actual or suspected fraud, and other illegal activity or security and technical issues; and/or
protect the rights, property and safety of our Clients and Daha or others, including to prevent death or imminent bodily harm.

Business Reorganisation: In some cases, Daha may choose to reorganise its business. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of Daha’s assets), Client information is typically one of the business assets that is transferred. If Daha intends to transfer information about you, Daha will notify you by email or by putting a notice on the Digital Experience.

Service Providers: Daha also engages third-party companies and individuals (such as payment processors and platform operators) to help us operate, provide, and advertise the Services. These third parties have limited access to your information, may use your information only to perform these tasks on our behalf, and are prohibited from disclosing or using your information for other purposes.

The types of third-party service providers that we work with include:

Third-Party Service Providers	What Information We Share
Try.be, our Platform provider	Basic Client InformationWellness HistoryWellness Preferences
Adyen, our payments processor	Basic Client InformationPayment Information
Zoho, our CRM system provider	Basic Client InformationWellness Preferences

This policy does not apply to the practices of third parties that Daha does not own or control or individuals that Daha does not employ or manage, except as otherwise provided for in the terms or as required by law. If you provide your information to such third parties in connection with your use of the services, different practices may apply to the use or disclosure of the information that you provide to them. While Daha requires these third parties to follow Daha’s privacy and security requirements, Daha does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Daha is not responsible for the privacy or security practices of these third parties. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these third party providers are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.

Where we share your information with our partners as described in this Policy, such partners will process your personal information in accordance with their own privacy policies. In some instances, while they are subject to Daha’s privacy and security requirements for vendors, these partners, not Daha, are responsible for the protection of personal information under their control.

How long we retain your data

Daha will retain your information only for as long as is necessary for the purposes set out in this Policy, or as needed to comply with our legal obligations under national applicable law. We decide how long we need information on a case-by-case basis and depending on the retention laws applicable.

The following factors typically affect the retention period:

Necessity for the provision of our Services: We keep your information as long as is necessary to provide the Services to you. This includes things like managing your bookings, taking payments, sending you service communications and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.

Consent-based processing of personal data: If we process personal data on the basis of consent (including consent to the extended storage), we store the data for as long as necessary in order to process it according to your consent or until you withdraw your consent.

Statutory, contractual or other similar obligations: Daha will retain and use your information to the extent necessary to comply with our legal obligations, for example, if we are required to retain your information to comply with applicable tax/revenue laws.

TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Daha will generally not process your personal data outside the European Economic Area (“EEA”). In the unlikely circumstances where your personal information is transferred outside of the EEA, we will ensure that the transfer is lawful in accordance with Chapter 5 of the GDPR.

Your rights

Certain privacy laws around the world, including the GDPR, provide individuals with rights and choices related to their personal information. Consistent with those laws, Daha gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. In addition, subject to applicable law, you may have certain rights with respect to your personal information, such as the following:

Right to access and portability: You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
Right to rectification: You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
Right to erasure: You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten. This right does not apply to certain data that we are required to retain by law.
Right to object to or restrict processing: You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
Right to withdraw consent: You have the right to withdraw your consent to our processing at any time. The lawfulness of Daha’s processing before you withdraw your consent will not be affected by such withdrawal.
Right to File a Complaint: If you are a resident in the EEA, Switzerland or the UK, you have the right to lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state.
- In Ireland, the relevant data protection authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737, email: info@dataprotection.ie.

In order to exercise any of the rights set out above, please contact us at help@dahawellness.com.

Contact us

If you are unhappy with how we process personal data or if you have any queries or feedback, we ask you to contact us by emailing hello@dahawellness.com.

Changes to this policy

We may change this policy from time to time. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.