THE TENTH CIRCLES - PRIVACY POLICY

Last Updated: 19th January 2026

Welcome to the privacy notice (the “Notice”) for “Tenth Circles”, a curated membership for mothers at similar stages of motherhood, which extends The Tenth method into everyday life. 

THE TENTH is the trading name for “Tenth Circles”  which is registered at 52 Ravenscroft Ave, London NW11 8AU (“CLIENT”; “we”; “us”; or “our”). The Tenth respects your privacy and is committed to protecting your personal data.

We are committed to protecting your personal information and your right to privacy. This Notice explains how we collect, use, disclose and safeguard your information when you sign up for and participate in our Tenth Circles WhatsApp community. 

By joining Tenth Circles and providing your information, you agree to the collection and use of information in accordance with this Notice.

We process your data in an appropriate and lawful manner, in accordance with the UK Data Protection Act 2018 (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR” or the “Regulation”), following its application on 25th May 2018.


1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This Notice aims to give you information on how Tenth Circles collects and processes your personal data when you sign up and use the service, including any data you may provide during the course of that engagement, such as your name, WhatsApp phone number, survey responses to join our waitlist, and information you share on WhatsApp with us and other mothers. Tenth Circles is designed for mothers and adults only and we do not knowingly collect data from children under 18, however we may collect personal data about your baby with your consent.

It is important that you read this Notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Notice supplements any other notices provided by us and is not intended to override them. Moreover, certain processing activities will require your express consent in order to be carried out, as specifically indicated below in this Notice.

Contact details

Our full details are:

Full name of legal entity: THE TENTH CARE LIMITED (Company number 15716371)

Name of data protection contact point: Hiba Siddiqui

Email address: info@tenthwellness.com

Postal address: NW11 8AU

Telephone number: +44 7432 536 792

You have the right to lodge a complaint at any time to the competent supervisory authority in your jurisdiction on data protection matters. We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


 2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

Kindly note that information relating to a legal person (for example, a company or legal entity) does not amount to personal data in terms of applicable data protection and privacy law. In that regard, the definition of personal is strictly limited to information which relates to a natural person.

On this basis, the collection and use of information such as a company name, its company number, registered office and VAT number (i.e. “Company Information”), does not amount to the processing of personal data and, in turn, does not give rise to data controller obligations and data subject rights. Where collected, we will naturally still treat and handle such Company Information in an appropriately confidential and secure manner. This is particularly relevant to those of our customers which are businesses (i.e. where the relationship with THE TENTH constitutes a business-to-business (B2B) relationship). 

We collect several types of information from and about users of our Tenth Circles community. 

Information you provide directly:

  • Contact Information: e.g. your name, phone number and email address

  • Personal Information: e.g. your baby’s birth date, and information about your hobbies and other preferences

  • Communication Content: Messages, photos (which will include photos of your child if you choose to share them), videos, and other content you share within your Circle on WhatsApp

  • Feedback & Testimonials: Your honest review of your Tenth Circles experience

  • Financial Data: Your bank account and payment card details 

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

Information collected automatically:

  • Usage Information: How you interact with our community and services

  • WhatsApp Metadata: Information provided through the WhatsApp platform (such as messages timestamps and read receipts permitted by WhatsApp)

  • Transaction Data: Includes details about payments to and from you, and other details of products and services you have purchased from us.

We also collect, use and share Aggregated Data 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. For example, we may aggregate your Usage Data to calculate the percentage of users that contributed on a daily basis in their Circle.  However, if 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 Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to 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 a product or service that you have requested). In this case, we may have to cancel your access to Tenth Circles or any other product or service necessary but we will notify you if this is the case at the time.


3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Contact, Personal and Financial Data by making an inquiry or by corresponding with us by WhatsApp, post, phone, email or otherwise. This includes personal data you provide when you:

    • Interact on WhatsApp;

    • apply, or place an order for and/or purchase any of our products or services;

    • request marketing to be sent to you;

    • use the contact form on our Website; or

    • give us some feedback.

  • Automated technologies or interactions. As you interact with Tenth Circles, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

  • 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;

    • advertising networks; and

    • search information providers.

    • Contact, Financial and Transaction Data from providers of technical, payment and delivery.


4. HOW WE USE YOUR PERSONAL DATA

We use the information we collect for the following purposes:

Community Operations 

    • To facilitate connections between mothers in our Tenth Circles community

    • To match you with other mothers who share a similar motherhood stage or similar interests 

    • To organise and manage community activities and discussions

Communication

    • To send you community updates, announcements, and relevant information 

    • To respond to your inquiries and provide customer support

    • To send marketing and promotional communications about our services (with your consent where required)

Service Improvement

    • To analyse and understand how mothers are engaging in their Circle

    • To improve and optimise our offering and user experience

    • To develop new features and products

Third-Party Sharing

    • To share information with trusted partners, practitioners and service providers who assist us in operating our community (e.g. private referral appointments)

    • To comply with legal obligations or respond to lawful requests


Legal Basis for Processing (UK GDPR)

We process your personal data under the following legal bases:

  • Consent: Where you have given explicit consent for us to process your personal information for specific purposes (e.g. marketing comms, survey responses)

  • Contractual Necessity: To provide you with access to Tenth Circles and its services

  • Legitimate Interests: To improve our services, ensure community safety, and operate our business effectively, provided your rights do not override these interests

  • Legal obligations: Where we are required to process your data to comply with applicable laws

Marketing

With your consent, we may send you marketing communications about:

  • New Tenth Circles features and services

  • Other Tenth product offerings 

  • Events and activities

  • Partner offers and promotions

  • Surveys and feedback requests 

You can opt out of marketing communications at any time by:

  • Clicking the unsubscribe link in any marketing message

  • Contacting us directly at info@tenthwellness.com

Even if you opt out of marketing, we may still send you service-related communications necessary for community operations.

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@tenthwellness.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without the need for obtaining your consent, in compliance with the above rules, where this is required or permitted by law.


5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your information with:

  • CRM and Database Providers: To store and manage community member information

  • Analytics Providers: To help us understand community usage and improve our services

  • Communication Service Providers: Including WhatsApp and future messaging platforms

  • Marketing Service Providers: To deliver promotional communications (with your consent)


All third party providers are contractually obligated to maintain the confidentiality and security of your information. 

We may disclose your information where required by law, court order, or governmental authority, or to protect the rights, property, or safety of Tenth Care Ltd, our users, or others. 

In the event of a merger, acquisition or sale of assets, your information may be transferred to the acquiring entity. 


6. DATA STORAGE AND SECURITY

Storage location

Your personal information is stored in our CRM database and on WhatsApp’s servers. We use reputable service providers with appropriate security measures. 

Security measures

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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Furthermore, we have also 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.


7. 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By and large, our retention of your personal data shall not exceed the period of five (5) years from the conclusion or termination of your contractual relationship with us. This period of retention enables us to use your data for the assertion or defence of possible future legal claims (taking into account applicable statutes of limitation and prescriptive periods). In certain cases, we may need to retain your personal data for a period of up to ten (10) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction Data).

In some circumstances you can ask us to delete your data. See Request erasure below for further information.

In other circumstances, we may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Kindly contact  us on info@tenthwellness.com for further details about the retention periods that we apply.


8. YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You may send an email to info@tenthwellness.com requesting information as to the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of £5.

  • Right to information when collecting and processing personal data about you from publicly accessible or third party sources. When this takes place, we will inform you, within a reasonable timeframe, about the third party or publicly accessible source from which we have collected your personal data.

  • Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:

    • there is no good reason for us continuing to process it;

    • you have successfully exercised your right to object to processing (see below);

    • we may have processed your information unlawfully; or

    • we are required to erase your personal data 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. Most commonly, this will be where further processing of the personal data is required by us for:

  • compliance with a legal obligation to which we are subject;

  • assertion, exercise or defence of legal claims (including possible future claims).

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. We will notify you if this is the case at the time.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.

  • Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 data, as above indicated. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please note that, in spite of such withdrawal, we may continue to hold onto your personal data (rather than erase) if there are specific legal reasons which justify us doing so. Main instances would be a legal obligation requiring us to continue to hold onto such data or for the purposes of legal claims.

If you wish to exercise any of the rights set out above, please contact us at info@tenthwellness.com

No fee usually required

You will not have to pay a fee to access your personal data (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 may 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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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 (1) month. Occasionally it may 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.


9. WHATSAPP-SPECIFIC INFORMATION

Current Platform

We currently use the standard WhatsApp Business Application for Tenth Circles. Your use of WhatsApp is also governed by WhatsApp’s own Privacy Policy and Terms of Service.

Future Platform Changes

We may transition to using the WhatsApp Business API or other messaging platforms. We will notify you of any significant changes to how we use messaging platforms. 

Platform Limitations

We do not control WhatsApp’s data practices. Please review WhatsApp’s privacy policy to understand how they handle your information. 


Conclusion

Any changes that we may make in the future to this Notice will be visibly posted on our website and, if appropriate, notified to you via email or WhatsApp.

If you have any questions regarding our privacy policy, or if you would like to send us your comments, please contact us or send us an email on: info@tenthwellness.com

Please check back frequently to see any updates or changes to this Policy.