PRIVACY POLICY

Emma Davies Wellbeing holds some information about you. By visiting www.emmadavieswellbeing.com you are accepting and consenting to the practices described in this policy. This website may only be used for lawful purposes by individuals seeking to purchase or enquire about products and services provided by www.emmadavieswellbeing.com.

This policy (together with our terms of use and any other documents referred to on it) outlines the basis on which any personal data we collect from you, or that you provide to us, through your use of our site emmadavieswellbeing.com (referred to as “we”, “our” and “us” in this privacy policy), including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or promotional emails, attend an online event, take part in a competition or any other method in which you give us your information (see below).

This document outlines how that information is used, who we may share that information with and how we keep it secure. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Usage of this site is entirely at your own risk. We will not accept liability for any loss or damage incurred by using this site. We are committed to protecting and respecting your privacy.

Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation and requests should be sent to hello@emmadavieswellbeing.com. This Privacy Notice is under regular review and was last reviewed in May 2021.

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 hello@emmadavieswellbeing.com.

This policy only applies to www.emmadavieswellbeing.com. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over other websites and the policy or terms of the website and you should check their policy before continuing to access the site. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting other sites.

1. WHAT WE DO

Emma Davies Wellbeing provides nutritional therapy services, life coaching and Reiki treatments and training to clients to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions.  Through nutritional therapy consultations, life coaching, healing treatments, dietary and lifestyle analysis and laboratory testing, we aim to understand the underlying causes of your health issues which we will seek to address through personalised dietary and lifestyle protocols, nutraceutical prescription (supplements) and coaching advice. In addition, we may also provide group workshops and training, seminars and corporate wellness events to educate groups about optimal health through nutrition and lifestyle measures. 

2. HOW WE OBTAIN YOUR PERSONAL DATA

We may collect and process the following data about you:

Direct interactions:

You provide us data in the following ways:

• By completing a health questionnaire or booking form
• During a discovery call or consultation
• By signing a terms of engagement form or contract
• By filling in forms on our site (or otherwise)
• Through emails, phone calls or by post
• By ordering our products or services
• By creating create an account on our site
• By taking credit card and online payment
• Subscribing to our service or publications;
• Requesting resources or marketing be sent to you;
• Entering a competition, prize draw, promotion or survey
• By downloading any eBooks or free resources
• When you provide feedback
• Attending a live or online talk, event, webinar or workshop

This may include the following information:

• Basic details such as name, address, contact details and next of kin
• Details of contact we have had with you such as referrals and appointment requests
• Health information including previous medical history, diet diaries, lifestyle, supplement and medicine details, functional test results, consultation notes and personalised nutrition and lifestyle plans.
• GP contact information
• Bank details 

We use this information in order to provide you with direct healthcare. We are therefore holding your personal data for legitimate interest.

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 through cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.

Third parties or publicly available sources:

We may receive personal data about you from various third parties and public sources as follows:

Technical Data from the following parties:

• Analytics providers such as Google based inside or outside the UK.
• Advertising networks such as Facebook, Twitter, Linkedin and YouTube based inside OR outside the UK.
• Search information providers such as Google based inside or outside the UK.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal, WePay, and Stripe based inside or outside the UK.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the UK.

This may include the following information:

• Identity Data such as your first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data such as your billing address, delivery address, email address and telephone numbers.
• Financial Data such as your bank account and payment card details.
• Transaction Data such as details about payments between us and other details of purchases made by you.
• Technical Data such as 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 such as your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data such as information about how you use our website, products and services.
• Marketing and Communications Data such as your preferences in receiving marketing communications from us and our third parties and your communication preferences.
• Sensitive data such as health information that you provide including your previous medical history, dietary, lifestyle, supplement and medicine details, functional test results, consultation notes, personalised nutrition and lifestyle plans and GP contact information.

Following completion of your healthcare services, we retain your personal data for the period defined by our professional association and registrant body, FNTP. This enables us to process any complaint you may make.  In this case the legal basis of our holding your personal data is for contract administration.

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.

Information we get from other sources:

We may obtain sensitive medical information from your during your consultation or in the form of test results from functional laboratory testing companies. We use this information to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.

We may obtain sensitive information from other healthcare providers.  The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.

3. WHY WE NEED THIS INFORMATION

We use information held about you in the following ways to help improve the service we provide you:

• To ensure that content from our site is presented in the most effective manner for you and for your computer.
• To ensure our own internal records are accurate and up-to-date.
• To use the information to help improve our products and services to you.
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
• To send you other information which we think you may find interesting, using the mail address and details you have provided to us.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.

4. HOW WE USE YOUR PERSONAL DATA

We act as a data controller for use of your personal data to provide direct healthcare.  We also act as a controller and processor in regard to the processing of your data from third parties such as testing companies and other healthcare providers.  We act as a data controller and processor in regard to the processing of credit card and online payments.

We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.  We will also take reasonable security measures to protect your personal data storage.

We may use your personal data where there is an overriding public interest in using the information eg; in order to safeguard an individual, or to prevent a serious crime.  Also, where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters, eBooks and free resources but this would be subject to you giving us your express consent.

5. DO YOU SHARE MY INFORMATION WITH OTHER ORGANISATIONS?

We will keep your information confidential and will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

• Our registrant body and our professional association, FNTP, for the processing of a complaint made by you.
• Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential.
• Anyone to whom we may transfer our rights and duties under any agreement we have with you.
• Any legal or crime prevention agencies and/or to satisfy any regulatory request eg, FNTP if we have a duty to do so or if the law allows us to do so

We may share your information with supplement companies and laboratory testing companies as part of providing you with direct healthcare.  We will not include any sensitive information.

We will seek your express consent before sharing your information with your GP or other healthcare providers.  However, if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

We may share your case history in an anonymised form with our peers for the purpose of professional development.  This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites.  We will seek your explicit consent before processing your data in this way.

6. WHAT ARE YOUR RIGHTS?

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.

If you want to access your data you must make a subject access request in writing to hello@emmadavieswellbeing.com Under special circumstances, some information may be withheld. We will respond within 20 working days from the point of receiving the request and all necessary information from you.  Our response will include the details of the personal data we hold on you including:

• Sources from which we acquired your information
• The purposes of processing the information
• Persons or entities with whom we are sharing the information

You have the right, subject to exemptions, to ask to:

• Have your information deleted.
• Have your information corrected or updated where it is no longer accurate.
• Ask us to stop processing information about you where we are not required to do so by law or in accordance with FNTP guidelines.
• Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, without hindrance from us
• Object at any time to the processing of personal data concerning you.

We do not carry out any automated processing, which may lead to automated decision based on your personal data.

If you would like to invoke any of the above rights then please email hello@emmadavieswellbeing.com

7. WHAT SAFEGUARDS ARE IN PLACE TO ENSURE DATA THAT IDENTIFIES ME IS SECURE?

We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

 Within the healthcare sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so and you have the right to access the information we keep or request that it is deleted.

We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

Emma Davies Wellbeing is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search for Emma Davies Wellbeing).

8. HOW LONG DO YOU HOLD CONFIDENTIAL INFORMATION FOR?

All records held by Emma Davies Wellbeing will be kept for the duration specified by guidance from our professional association FNTP.

9. WEBSITE TECHNICAL DETAILS

We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual and we will not collect personal information in this way.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.

Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

10. ANALYTICS

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

11. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. However, we advise that you check this page regularly to keep up to date with any necessary changes.

12. COMPLAINTS

If you have a complaint regarding the use of your personal data then please contact us by emailing the Data Controller at
hello@emmadavieswellbeing.com and we will do our best to help you.

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.