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Privacy Policy

The ‘Diabetes Lifestyle Doctors’ brand and our website www.diabeteslifestyle.com are fully owned and operated by Pro Healthology Limited. Pro Healthology Limited (collectively referred to as “we”, “us” or “our” in this privacy policy) 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 it from) 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. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website, including when you sign up to our newsletter, subscribe to our services, submit information to us, take part in a competition or provide feedback.

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 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 privacy policy supplements the other notices and is not intended to override them.

Controller

Pro Healthology Limited is the controller and is responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Pro Healthology Limited

Name or title of data privacy manager: Dr Amanda Porch

Email address: [email protected]

Postal address: Diabetes Lifestyle Doctors, c/o Pro Healthology Limited, Salvus House, Aykley Heads, Durham, DH1 5TS, United Kingdom

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 28/10/2022 and historic versions can be obtained by contacting us.

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

This 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.

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 which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account, partial payment card details and purchase history through third-party payment providers.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you (with and without promotions), your interests, preferences, feedback, testimonials, reviews, optional survey responses, optional questionnaire responses, posts on our branded public and private social media and Google pages.

Usage Data includes information about how you use our website and services.

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

  • We may also collect personal information that is special category data (Health Data), as explained in detail in the next section.

Health Data We Collect About You

Health Data when disclosed by you to us or our systems when signing up, making enquiries, using our site or directly to a member of our team. This includes health metrics, examples (although not limited to) height, weight, waist circumference, blood pressure, laboratory results (includes blood results such as HbA1C) and PAM scores. Health data may also include consultation notes, past medical history, medications, allergies, treatments, medical devices, social history and any other relevant medical history. Health data may be viewed by our healthcare team where clinically indicated. This data is kept in accordance with UK governing and regulatory bodies, and therefore can still be disclosed in the interests of crime prevention and safeguarding issues to protect you or others from harm. It can also be disclosed under other certain circumstances in accordance with the law.   

  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose, including research purposes and analytics. 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 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.

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 with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, 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:

Interactions with us: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our services;

create an account on our website;

‘take our quiz’ on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion, questionnaire or survey; or

give us some feedback or a testimonial.

Data we automatically collect through technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. From cookies, we may deliver advertisements and an improved experience for you, based on your activity on our website or your activity on third party websites. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

Multiple analytics providers, for example, Google, which is based outside the EU;

advertising networks, marketing partners, business partners;

search information providers; and

social media platforms.

Typeform through our ‘Take Our Quiz’ website link or by reaching this point through another means. 

Klaviyo follow up emails through our ‘Take Our Quiz’ website link or by reaching this point through another means. 

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

Identity and Contact Data from data brokers or aggregators.

Identity and Contact Data from publicly availably sources.

Social Media Plugins and Data We Collect About You 

Our Website contains functionalities that enable you to start interactions between our Website and third-party platforms and services, including social media networks such as Facebook, Instagram and Twitter.

If you have an account on one of these social media platforms and you are logged in via your social media accounts, these platforms may connect your visit to our Website and your behaviour with the personal data they hold about you and use the combined data for other purposes.

Even when you do not have an account on one of these social media platforms, they may still collect personal data such as your IP address, information regarding your device and your behaviour across our Website.

●      Facebook Like Button:

We have an embedded ‘Facebook’ link buttons on our web pages and it allows you to access and ‘Like’ our Facebook page.

This Facebook ‘Like’ button may collect the following personal data about you:

-Your IP address and your browser user agent

-Information about how you interact with the Like button itself. This includes monitoring your browsing activity, when and how you click on the Like button and on which page

-Information about actions you take on the Like button, with the information related to your Facebook account may be combined

For more information about how the Facebook Like button collects and processes personal data, please visit the Facebook Privacy Policy’s relevant sections:

https://www.facebook.com/policy.php

●      Twitter Button

If you interact with the Twitter button on our Website, you will connect to Twitter.com.

Twitter may collect personal data about you such as your IP address and your web browser user agent.

Twitter widgets may store cookies on your browser or use other tracking technologies and record how you interact with the Twitter button.

This includes a correlation of your Twitter account information with the specific actions you take within the Twitter button such as your clicks.

For more information, please visit Twitter’s Privacy Policy:

https://twitter.com/en/privacy

●      Instagram Plugin

Our Website includes an Instagram widget that enables you to view and interact with our Instagram page.

If you are logged in to your Instagram account, Instagram may link your visit to our Instagram page with your account information

For more information about what type of personal data Instagram may collect about you and how your data may be processed, please visit the Instagram Privacy Policy:

https://help.instagram.com/519522125107875

●      Facebook group

We operate private Facebook groups where we connect with our customers/patients and enable our customers/patients to share their experiences.

We are joint controllers with Facebook (Facebook Ireland Ltd) in accordance with article 4(7) of the UK-EU GDPR.

The controllers process your personal data such as your name, other basic details and your browsing activities when you join and interact with the relevant Facebook group.

●      Legal Basis

We create and operate Facebook groups to help our customers/patients share their experiences and connect with others in similar circumstances and to create a sense of community. We rely on ‘Legitimate Interests’ ground under article 6.1 (f) GDPR for the processing of your personal data for these purposes.

●      Processing of Your Personal Data by Facebook

Facebook may collect and process data about you as the data controller. To learn more about how Facebook collects and uses your personal data, please refer to Facebook’s own Privacy Policy at:

https://www.facebook.com/policy.php

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 or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us. This aspect is covered further in the marketing section below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please 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

(b) Contact

(c) Health

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

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(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 enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, site safety and security, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Usage

(c) Technical

(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

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, improve your user experience, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our 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 services that may be of interest to you. To notify you about changes to our services.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our services and grow our business)

To market our services by posting testimonials and feedback about us through our site or a third-party site. Please note that testimonials will only be published with your express consent and will be limited to your first name, age, gender, location +/- photograph

(a) Identity

(b) Contact

Necessary for our legitimate interests (to advertise our services and provide testimonials and feedback from existing users to potential customers)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our marketing partners may contact you with your opt-in consent by telephone, email, post, SMS or other methods. If you wish to unsubscribe from marketing campaigns, then please email us at [email protected] or choose to unsubscribe by clicking the relevant link within the material received.

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 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 services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links 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 service purchase, 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, and where this is a requirement of or permitted by the law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

External Third Parties as set out in the Glossary.

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 may transfer aggregated and anonymised personal data to a country outside of the UK for further use as outlined with the purposes stipulated elsewhere in this policy, and for research purposes. 

We implement appropriate technical, organisational and contractual measures as specified in section 10 below.

When our employees, contractors and/or staff access personal data from outside of the UK, we put in place appropriate technical, organisational and contractual measures to ensure that personal data is protected both in transit, at rest and in use.

Should you have any questions regarding these measures feel free to contact us.

7. Data security

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.

We also implement appropriate organisational and contractual measures for our employees’ access to our IT systems and personal data. We have ‘Remote Access Policy’ and ‘Bring Your Own Device (BYOD) Policy’ in place. These two policies address how our employees can access our IT systems and databases and the security measures that they need to adhere to.

Furthermore, we also implement state-of-the-art data security measures on all devices used by our employees, contractors and staff to access our IT systems and databases.

Data storage for any 1:1 coaching interaction with our staff, which includes a special category (health data) is stored encrypted at rest and in transit. Your data is securely stored within the Microsoft 365 Cloud, our website, and is all backed up within secure servers based within the United Kingdom. 

We have 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.

8. Data retention

  • How long will you use my personal data be held for?

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. 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.

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

  • In some circumstances, we may 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. 

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. A summary is listed here, but please see our glossary to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee is 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 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.

How to exercise your rights 

If you choose to exercise your legal rights listed above, you can resort to either of the following methods to submit your request:

●      Request via Post

Postal address: Diabetes Lifestyle Doctors, c/o Pro Healthology Limited, Salvus House, Aykley Heads, Durham, DH1 5TS, United Kingdom

●      Request via Email

Email us at: [email protected]

When you submit your request via those methods, please include the following along with your request:

●      Provide us with your name & surname and a simple description of your relationship with Us,

●      Describe your request and its scope,

●      Your contact details, including your email address.

We handle sensitive data and reserve the right to ask for additional details and documents proving your ID and your relationship with Us.

Your Right to Lodge a Complaint With The Supervisory Authorities 

You can file a complaint with the relevant Data Protection Authorities under the applicable laws related to the processing of your Personal Data by Us.

If you are located in the UK & EU, you can contact the ICO (UK Data Protection Authority) via the following ways and submit your complaint regarding the handling of your personal data:

The ICO’s Postal Address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 SAF

Helpline Number: 0303 123 1113

ICO Website: https://ico.org.uk/

For more information on how to submit a complaint, please check the relevant section on the ICO’s Website:  https://ico.org.uk/make-a-complaint/

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

Note in most circumstances data will be shared in an aggregated format, meaning that it will not be in a form that directly identifies you and therefore will not constitute personal data.

Service providers who provide IT, statistics, marketing, analytics and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, healthcare professionals, our regulatory bodies, and insurers who provide consultancy, banking, legal, finance, professional collaboration, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where 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.

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 to 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.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

LAST UPDATED 28TH OCTOBER 2022