1. IMPORTANT INFORMATION ABOUT WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
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.
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 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 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.
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.
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To perform our contract with you which will include:
(a) Online education courses
(b) Coaching 1-2-1 sessions
(c) Nutritional Therapy and Personalised Health Packages
(c) Services-related data
(d) Health data
(f) Marketing and Communications
|(a) Performance of a contract with you. The data may be shared with third parties (i.e., Teachable for the courses, DNAfit testing) relating to a product that includes a DNA test and coaching session.
(b) Necessary for our legitimate interests (to keep our records updated in order to provide a better service to you)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
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.
We will obtain your expressed opt-in consent before we share your personal data with any third party for marketing purposes.
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.
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 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?
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.
With WIM you’ll learn to master your emotions, breakthrough barriers to weight loss,
nourish your mind and body, and feel confident.
With WIM you’ll learn to master your emotions, breakthrough barriers to weight loss, nourish your mind and body, and feel confident.