Heka Privacy Notice

This Privacy Notice sets out how we, GoSweat Ltd. (the legal entity operating the “Heka” brand) use, protect and share the personal information that we collect from you when you use our website, when you use our services, when you apply for a job with us or when you interact with us or contact us in any other way.

We do not knowingly collect personal information relating to children, and our website is not intended for children.

WHO ARE WE?

We, GoSweat Ltd, provide a flexible employee benefits programme with a focus on wide-ranging and holistic wellbeing benefits, known as Heka. We are a Data Controller, which means that we are responsible under Data Protection laws for ensuring that your personal information is protected.

Our full company details are:

Legal entity name: GoSweat Ltd

Company registration: Registered in England and Wales (Company number 10399802)

Registered office: Heath Poole Heath Lane, Willaston, Neston, United Kingdom, CH64 1TR

Email address: sayhello@hekahappy.com

You can contact us at the above address if you have any questions about this Privacy Notice, or if you would like to exercise any of your rights under Data Protection Laws, which we set out below.

Where you are accessing the Heka employee benefits programme or platform as an employee:–

Where our services are provided to the organisation you are working for, and you are provided with access to use the services as an end user, we act as a Data Processor. This means that we process the personal data provided to us when you use the services or you interact with us, on behalf of (and on the instructions of) your organisation. Your use of our services is governed by your organisation’s own policies, and your organisation is the Data Controller ultimately responsible for this processing and should be contacted directly if you have any queries relating to their use of your information and/or your use of our services.

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WHAT TYPES OF INFORMATION DO WE COLLECT FROM YOU?

We may collect, use, store and transfer different kinds of personal information about you such as:

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• Identity and Contact Information including your first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender, your business or your home address, email addresses and telephone numbers and your social media handles.

• Financial and Transaction Information including your bank account and payment card details, details about payments to and from you and other details of products and services you have purchased from us.

• Technical and Usage Information including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our websites and information about how you interact with and use our websites, products and services.

• Profile Information including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Marketing and Communications Information including your preferences in receiving marketing from us and our third parties and your communication preferences.

If you are a job applicant we may also collect the following information from you:

Application Information including your contact information, such as your name, email address, phone number, city, country, and any other contact information; details related to your work experience, such as your CV or resume, cover letter, academic qualifications, transcripts; information about the type of employment you are looking for or may be interested in, including targeted compensation, benefits and other job preferences; publicly available information from publicly available sources relevant for the hiring process, e.g. your LinkedIn profile; and other information provided by you in the hiring process.

• Interview Information including personal data collected from interviews and outcomes of any recruiting exercises you complete, including personality/reasoning ability tests and, for certain roles, recordings of presentational based interviews.

• Background Check Information including information received from internal and external reference and background checks, including criminal records at offer stage only (if applicable for the position you have applied for, and as permitted by applicable laws).

• Immigration and Visa Information including information related to your immigration status and visa requirements.

• Voluntary Demographic Information on a voluntary basis, we may ask you to provide us with demographic information such as gender identity and, as permitted by applicable laws in some countries, race, ethnicity, and veteran status. This information will only be used to help us to evaluate and improve our diversity and belonging efforts on an aggregate level. This information will be processed separately from your application and whether you choose to answer will not affect your job application.

We may also anonymise and aggregate information (so that it does not directly (or indirectly reveal your identity) which we may then use to calculate the percentage of users accessing a specific website, programme or platform feature in order to analyse general trends in how users are interacting with our website, programme or platform, and the benefits users select, to help improve and develop the website and the products and services that we offer.

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HOW AND WHY DO WE USE YOUR PERSONAL INFORMATION?

How your information is collected:

When you interact with us: you may share your personal information with us when you provide information using an online form or when you correspond with us by email, post, telephone or any other means or when you use our services, programme or platform. If you are an employee of our customers and are a recipient or user of our services, your organisation will share some personal information about you with us so we can provide you with access to our platform. If you are a job applicant, you may share your information with us as part of our recruitment process.
Automated Technologies and Cookies: as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our cookie policy https://www.hekahappy.com/legal/cookie-policy for further details.

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How your information is used:

The law requires us to have a legal basis for everything that we do with your personal information falling under one of the following categories:

Performance of a contract with you: Where we need to perform a contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and/or enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to.
Consent: We rely on consent only where we have obtained your active agreement to use your personal information for a specified purpose, for example if you “opt-in” to receive marketing emails from us.
Vital Interests: We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

We use your personal information in a number of different ways and for different reasons – the tables below set out what we do and why:

Identity and Contact Information

What do we do?

Why do we do it?

What is the legal basis?

Identify you when you visit our websites or you contact us for any reason and to register you as a new user.

So that we know who we are talking to, and to enable us to set you up with an account so that you can purchase our products and services.

Legitimate interests.

Performance of a contract with you.

To process any order that you place and provide you with access to the products and/or services that you have purchased.

So we can provide you with the products or the services that you purchase.

Performance of a contract with you.Legitimate interests.

To send you service updates, order confirmations and updates to this Privacy Notice and/or our terms and conditions.

So we can keep you informed of any changes to our services and to let you know about any issues with your orders/purchases.

Performance of a contract with you.
Legitimate interests.
Legal obligation.

To send you information about our products and services and to invite you to events.

So we can let you know about products and services that we offer that you might be interested in, and any events that we hold that you might like to attend.

Consent.
Legitimate interests (where you have purchased a product or service from us already, and the marketing relates to connected products, services or events.)

To send you surveys and to ask for feedback.

To offer you the opportunity to let us know how we are doing, or to let us know your views on another subject.

Legitimate interests.

To manage your registration and attendance at a HEKA event.

So that we can coordinate that event, including sending you details in advance, registering you on the day and following up with you afterwards.

Performance of a contract with you.
Legitimate interests.
Consent (in relation to any follow-up communications)

Financial and Transaction Information

What do we do?

Why do we do it?

What is the legal basis?

Take payments for the products and services that you order.

To facilitate payment for our products and services and to issue any refunds where necessary.

Legitimate interests.

Performance of a contract with you.

To keep a record of our transactions with you.

For accounting purposes.

Legal obligation.

Technical and Usage Information

What do we do?

Why do we do it?

What is the legal basis?

Identify you when you visit our websites.

To provide you with the best possible user experience.

Legitimate interests.

Monitor visitors to our websites and analyse their use of the websites, and perform tests on our IT systems.

To protect our websites and our IT systems from fraud or cyberattacks and to improve our websites and our services and our IT security.

Legal obligation.

Profile Information

What do we do?

Why do we do it?

What is the legal basis?

Send you relevant marketing material based on your profile information.

To make sure that the marketing that we send to you is relevant and is something that you are interested in receiving.

Monitor visitors to our websites and analyse their use of the websites, and perform tests on our IT systems.

Marketing and Communications Information

What do we do?

Why do we do it?

What is the legal basis?

We keep a record of your communication preferences (your “opt ins” and “opt outs”)

So we can make sure that you only receive the communications from us that you would like to receive and so we can update our records if you change your mind.

Legitimate interests.

Legal obligation.

Application Information

What do we do?

Why do we do it?

What is the legal basis?

To communicate with you throughout our recruitment process.

So we can process your application.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To assess your qualifications, skills and suitability for the considered job.

So we can work out whether we want to hire you.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To verify your provided information and undertake background checks.

So we can make sure you are who you say you are.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To consider you for, and inform you about, future job opportunities.

So we can potentially hire you in future.

Consent.

To prepare your employment agreement if you are offered a job.

So we can employ you.

Performance of a contract with you.

To assist you with obtaining an immigration visa or work permit.

So we can help you work.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

Compliance with legal obligations.

What do we do?

Why do we do it?

What is the legal basis?

To communicate with you throughout our recruitment process.

So we can process your application.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To assess your qualifications, skills and suitability for the considered job.

So we can work out whether we want to hire you.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To verify your provided information and undertake background checks.

So we can make sure you are who you say you are.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To consider you for, and inform you about, future job opportunities.

So we can potentially hire you in future.

Consent.

To prepare your employment agreement if you are offered a job.

So we can employ you.

Performance of a contract with you.

To assist you with obtaining an immigration visa or work permit.

So we can help you work.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

Compliance with legal obligations.

To comply with applicable laws, regulations, legal processes or enforceable governmental requests, e.g. immigration and visa laws and requirements.

So we can comply with applicable laws.

Compliance with legal obligations.

Interview Information

What do we do?

Why do we do it?

What is the legal basis?

To assess your qualifications, skills and suitability for the considered job.

So we can work out whether we want to hire you.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To consider you for, and inform you about, future job opportunities.

So we can potentially hire you in future.

Consent.

Background Check Information

What do we do?

Why do we do it?

What is the legal basis?

To verify your provided information and undertake background checks.

So we can make sure you are who you say you are.

Legitimate interests in recruiting new employees and managing our recruitment process in order to properly resource, develop and grow our business.

To comply with applicable laws, regulations, legal processes or enforceable governmental requests, e.g. immigration and visa laws and requirements.

So we can comply with applicable laws.

Compliance with legal obligations.

Immigration and Visa Information

What do we do?

Why do we do it?

What is the legal basis?

To prepare your employment agreement if you are offered a job.

So we can employ you.

Performance of a contract with you.

To comply with applicable laws, regulations, legal processes or enforceable governmental requests, e.g. immigration and visa laws and requirements.

So we can comply with applicable laws.

Compliance with legal obligations.

Voluntary Demographic Information

What do we do?

Why do we do it?

What is the legal basis?

To evaluate and improve our diversity and belonging efforts on an aggregate level.

So we can track, analyse and work on diversity and inclusion within our business.

Consent.

In limited circumstances we may process any of your personal information we hold to the extent necessary to defend, establish and exercise legal claims or to comply with legal or regulatory obligations.Where we need to collect personal data due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). We will notify you of this at the time.

‍HOW DO I MANAGE MY MARKETING PREFERENCES?
‍When you fill in one of our online forms on our website (such as subscribing to receive our marketing communications/newsletter, booking a demo, or during the registration process when you set up a user account, you may be asked to indicate your preferences for receiving direct marketing communications from us. If you change your mind you can opt-out at any time - you can use the “unsubscribe” link at the bottom of any marketing communication that we send to you. You can also contact us at sayhello@hekahappy.comWe will always get your express consent before we share your personal information with any third party for their own direct marketing purposes.Please note that if you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, appointment reminders, updates to our user Terms and Conditions, checking that your contact details are correct.

‍WHAT ABOUT COOKIES?
‍For more information about the cookies we use and how to change your cookie preferences, please see https://www.hekahappy.com/legal/cookie-policy

‍WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
‍We may share your personal information with third parties who provide services to us, for example, our IT, communications, CRM, email and marketing automation and hosting providers. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.The third party service providers that we currently use are:

Service provider

Service description

Location

GCP

Provision of hosting infrastructure

London

AWS

Provision of hosting infrastructure

London

SendGrid

Email processing

USA

MailChimp

Email processing

USA

Stripe

Payment processing

USA

Wise

Payment processing

Global

Shopify

Order processing/fulfilment

Europe

New Relic

Monitoring

Europe

Zapier

Order fulfilment notifications

USA

When you use our platform to select a wellbeing benefit, it will be necessary for us to share some of your personal information with the benefits provider itself. We will share the minimum information required in order to enable you access to the benefits you have requested. For details of these benefit providers, please review the benefit provider information provided at the point of selection.

‍Third parties in case of a legal requirement. We also disclose your personal information if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police/tax authorities, such as HMRC in the UK).

‍Third parties in case of a corporate transaction. In addition, information about our customers and users, including personal information, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors.We may provide anonymous information to analytics and search engine providers to help us improve and optimise our services. We will only share this information in a form that does not directly identify you.
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‍WHAT HAPPENS IF WE SHARE YOUR INFORMATION WITH ORGANISATIONS OUTSIDE OF THE UK?
‍Whenever we transfer your personal information out of the UK or the EEA to service providers or benefit providers, we ensure a similar degree of protection is afforded to it by ensuring that the necessary safeguards are in place, for example:
- We will only transfer your personal information to countries that have been deemed by regulators in the UK or the EU to provide an adequate level of protection for personal information; or
- We may use specific standard contractual terms approved for use in the UK and EU which give the transferred personal information the same protection as it has in the UK and EU. For more information about these safeguards, please contact us at Sayhello@hekahappy.com.

‍HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
‍We are committed to protecting individuals’ personal information. We put in place appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal data in our systems. These include information security, information management and data protection policies. To protect your personal information, we encourage you to:
- use a strong password which you only use for your account with us;
- never share your password with anyone;
- limit access to your computer and browser; and
- log out once you have finished using the services on a shared device.
If other individuals have access to your account, then they can access personal data, controls and the details of the benefits available, and selected by you, in your account. For example, you might have allowed someone to use your account on a shared device.It's your responsibility to only allow individuals to use your account where you are comfortable sharing this personal information with them. Anyone else's use of your account may impact your personalised recommendations.

‍HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
‍We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For further information about specific retention periods, please contact us at sayhello@hekahappy.com.

‍WHAT ARE YOUR RIGHTS IN RELATION TO THE PERSONAL INFORMATION WE HOLD?
‍You have a number of rights under data protection laws in relation to your personal information. You have the right to:
- Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal information for direct marketing purposes.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.If you wish to exercise any of the rights set out above, please contact us at Sayhello@hekahappy.com
‍No fee usually required
‍You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
‍What we may need from you
‍We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
‍Time limit to respond
‍We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

‍CONTACT US IF YOU HAVE A QUESTION OR A COMPLAINT
‍You have the right to make a complaint at any time to the relevant data protection regulator. In the UK this is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any regulator, so in the first instance please contact us at Sayhello@hekahappy.com or by post to:Heath Poole Heath Lane, Willaston, Neston, United Kingdom, CH64 1TR
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‍UPDATES TO THIS PRIVACY NOTICE
‍We may update this Privacy Notice from time to time and we keep it under regular review. This version was last updated November 2025.

‍THIRD-PARTY LINKS Our websites 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.