PRIVACY POLICY FOR IN TUNE NUTRITION

This is the privacy notice of In Tune Nutrition. In this document, "we", "our", or "us" refer to In Tune Nutrition.

Introduction

  1. This is a notice to inform you of our policy about all information that we record about you. Alongside our terms and conditions, it sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately, or to choose not make use of our services.
  3. At In Tune Nutrition, we take seriously the protection of your privacy and confidentiality. We understand that all users of our services and visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
  4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  6. In Tune Nutrition (Gemma Price) is registered with the Information Commissioner’s Office (ICO) as a data controller. A copy of the registration is available through the ICO website.
  7. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at org
  8. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or otherwise.
  9. This document does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed.

Who we are

In Tune Nutrition is the data controller and we are responsible for your personal data. You can contact us by email at: gemma@intunenutrition.co.uk or by telephone on: 07899 891 256.

What we do

In Tune Nutrition provides nutritional therapy services 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, dietary and lifestyle analysis and biochemical testing, we aim to understand the underlying causes of your health issues which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.

In Tune Nutrition also provides nutrition services to groups through workshops and seminars both in person and online. Through these services, and our blogs and newsletters, general advice on healthy diet and lifestyle practices is provided alongside information on links between symptoms and underlying nutritional or biochemical imbalances and lifestyle factors.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

  • verify your identity for security purposes
  • sell products to you
  • provide you with our services
  • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services including our newsletters, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at gemma@intunenutrition.co.uk, or in the case of receiving newsletters, by unsubscribing from these communications at any time by following the link at the bottom of the email. However, if you do so, you may not be able to use our website or our services further.

3. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

4. Information provided in order to provide you with direct healthcare

You may provide us with personal data in order for us to provide you with nutritional therapy and nutrition services in the following ways:

  • by completing a nutritional therapy questionnaire
  • by signing a terms of engagement form
  • during a nutritional therapy consultation
  • through email, over the telephone or by post
  • by taking credit card and online payment
  • by filling in forms on our website

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 your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans
  • GP contact information
  • bank details

We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.

After we have finished providing healthcare services to you we retain your personal data for the period defined by our professional association British Association for Nutrition and Lifestyle Medicine (BANT) and registrant body, the Complementary & Natural Healthcare council (CNHC). 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.

In the provision of direct healthcare, we act as a data controller for the use of your personal data. 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.

Within the health 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 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 password and/or secure key. 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.

5. Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

  • tagging an image
  • clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
  • leaving comments on blog posts

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at gemma@intunenutrition.co.uk

6. Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7. Information relating to your method of payment

At the point of payment, you are transferred to a secure page on the website PayPal or if paying by credit/debit card payment is taken via Stripe payment gateway. No payment details are kept on our website or servers. All payment data is fully secure and safe and processed through stripe who is fully PCI compliant.

8. Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Use of information we collect through automated systems when you visit our website

9. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed in our site
  • to record your answers to surveys and questionnaires on our site while you complete them
  • to record the conversation thread during a live chat with our support team

10. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

11. Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information

12. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. This data would not be personally identifiable to you.

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

We may also 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.

13. Sharing your information

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

  • 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
  • Our registrant body, CNHC and our professional association, BANT, for the processing of a complaint made by you
  • Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. by CNHC) 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 biochemical testing companies as part of providing you with direct healthcare.  This will be limited to personal information except in certain cases when further details are reasonably deemed to benefit the case assessment and positively impact the health advice we provide.

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 (so that you cannot be identified) 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.

14. Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

15. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

16. Data may be processed outside the European Union

Our website is hosted in the United Kingdom

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business, such as testing or supplement companies.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

Other matters relating to our website

17. Use of website by children

  • We do not sell products or provide services for purchase by children, nor do we market to children.
  • If you are under 18, you may use our website only with consent from a parent or guardian

18. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

Access to your own information

19. Access to your personal information

  • At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
  • To obtain a copy of any information that is not provided on our website you may send us a request at gemma@intunenutrition.co.uk
  • After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
  • Our response will include the details of the personal data we hold on you including
    • Sources from which we acquired the information
    • The purposes of processing the information
    • Persons or entities with whom we are sharing the information.
  • This will be provided in a structured, commonly used and machine readable format. You have the right to transmit this data to another controller, without hindrance from us.

20. Removal of your information

You have the right, subject to exemptions, to ask us to have your information deleted, or to ask us to stop processing information about you where we are not required to do so by law or in accordance with the BANT or CNHC guidelines.

This may limit the service we can provide to you.

If you would like to invoke this right then please write to the data controller at gemma@intunenutrition.co.uk.

21. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

22. How you can complain

  • If you are not happy with our privacy policy or if have any complaint regarding the use of your personal data then please tell us by writing to the data controller by email. Our address is gemma@intunenutrition.co.uk.
  • If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
  • If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/ our you can contact them by telephone on 01625 545 745 or 0303 123 1113.

23. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

  • to provide you with the services you have requested;
  • to comply with other law, including for the period demanded by our tax authorities;
  • to comply with guidance from our professional association, BANT;
  • to comply with the requirements of our professional indemnity insurance;
  • to support a claim or defence in court.

24. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our services or our website.

25. Review of this privacy policy

We may update this privacy notice from time to time as necessary. We may notify you of changes to this privacy policy by email. The terms that apply to visitors to our website are those posted on our website on the day you use our site. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

This policy was last updated on 28th October 2019