Privacy Policy

INTRODUCTION

Welcome to Weight in Mind Ltd.’s privacy policy.

Weight in Mind Ltd. respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit us from) and/or use our services and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION ABOUT WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you and/or your company information on how Weight in Mind Ltd. collects and processes your personal data through your use of this website and all other elements of our services. This includes any data you or your employees may provide through this website when you sign up to our newsletter or purchase our products or services or any data you might provide or that we might share via email, google forms, as part of a corporate contract or verbally as part of your engagement in the courses and clinic services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Weight in Mind Ltd. is the controller and responsible for your personal data collectively referred to as “Company”, “we”, “us” or “our” in this privacy policy.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us using the online contact form.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 1st October 2019.

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.

THIRD-PARTY LINKS

The website 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 policy of every website you visit.

THIRD PARTY CLINICAL SERVICES

In addition, if you use our clinic services we may share your personal data with laboratories or with your medical doctor as appropriate with your permission. If you engage with our training courses online or offline we might share your information as detailed in clause 4.

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).

We may collect, use, store and transfer different kinds of personal data about you that you consent to provide explicitly when you purchase our products, courses and clinic services which we have grouped together as follows:

• Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth and gender].
• Contact Data includes [billing address, delivery address, email address and telephone numbers].
• Services-related Data includes [certain details that you may provide explicitly in relation to your personal life and circumstances through the process of our services provided to you. This may include information such as goals, ambitions, personal beliefs (i.e. lifestyle, food practice, health, capabilities to change), familiar and social environment, that are needed to properly provide your services.
• Health Data includes [certain details that you may provide explicitly in relation to your health through the process of our services provided to you. This may include information such as weight, current health status (i.e. fitness), health check questionnaire  (i.e. medical history, treatments and allergies, medication), DNA information (diet health lifestyle and fitness)
• Transaction Data includes personal data and Paypal account information necessary to facilitate the transaction, including details about payments to and from you and other details of services you have purchased from us.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 privacy policy.

We do not collect the following Special Categories of Personal Data about you: race or ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, 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 the 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 our services). In this case, we may have to cancel the contract but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We collect the data you provide in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

• (a) create an account on our website;
• (b) Subscribe to our services or publications and provide your consent;
• (c) Request marketing to be sent to you;
• (d) Enter a competition, promotion or survey; or
• (e) Give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources.We will receive personal data about you from various third parties [and public sources] as set out below:

Technical Data from the following parties:

(a)  analytics providers such as Google;
(b)  advertising networks such as Facebook and Instagram;
(c)  search information providers such as Google.

For more information, please visit our Cookie Policy.

Contact and Transaction Data from providers of technical, payment and delivery services such as Paypal.

For more information, please visit https://www.paypal.com/va/webapps/mpp/ua/privacy-full

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will obtain your expressed opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out link on any marketing message sent to you OR by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a course/service purchase, registration, course/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

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 your knowledge or 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 personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Specific third parties listed in the table Purposes for which we will use your personal data above.
• We may disclose your personal data to our insurers and/or professional advisers as much as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, in line with this Privacy Policy. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within Weight in Mind Ltd. This might involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by  ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data 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 data 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.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

As regards the Services-related Data and the Health Data, we aim to keep this information for as long as you are a customer, because it will help us to keep track of your information in order to provide our services and for a period of 7 years thereafter in case you are a returning customer. After that period, the information will be kept anonymised for statistical and investigation purposes. 

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will 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.

HOW DO YOU STORE MY PERSONAL DATA? 

We may store and process any information collected in accordance with this privacy policy electronically. Said information will be stored in the cloud by contracting with well-known third party vendors. Any electronic data kept on devices will be saved in a secure folder using a unique password to protect data against accidental loss.

When we need to communicate with you regarding your personal data, such as sensitive health data, recommendations including test results and health check questionnaire answers we will communicate via encrypted email and send you a specific password to access the contents, OR we will share information with you via a personal secure google drive file from where you can view, download and upload your clinic documents.

If you do not want to receive your email encrypted, you can request this in writing via email stating: 

“I confirm I wish to receive all communications with you via standard email and I understand the associated data protection risks” 

Is understood that you acknowledge the risk involved. 

Basic generic information including instructions for use of purchased services and products will be sent via standard email.

Hard copies of registration documents and consultation notes will be kept for 7 years as per the terms of our insurance. After which data stored in electronic form will be destroyed, to the extent electronically possible. 

8. YOUR LEGAL RIGHTS

Request the transfer 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. 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.