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Privacy & Cookie Policy

BACKGROUND:

The Gut Health Clinic Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of our clinic clients and of everyone who visits our website,  theguthealthclinic.com (“Our Site”).  We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy & Cookie Policy carefully and ensure that you understand it. 

1. Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

“Client”

means a client who engages the services of a dietitian or health psychologist through the Gut Health Clinic Ltd; 

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 15, below;

“Cookie Law”

means the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2003 (SI 2003/2426) (as amended) and the relevant parts of the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR); and;

“Data Protection Legislation”

means all applicable data protection and privacy legislation in force from time to time in the UK including the UK GDPR; the Data Protection Act 2018 (DPA 2018) (and regulations made thereunder); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including the privacy of electronic communications); and

“UK GDPR”

means the retained EU law version of General Data Protection Regulation ((EU) 2016/679).

2. Information About Us

Our Site is owned and operated by The Gut Health Clinic Ltd, a company registered in England & Wales under company number 12299130, whose registered office address is at 7 Bell Yard, London, Bell Yard, London, England, WC2A 2JR.  The Gut Health Clinic Ltd, referred to as “we” or “us” in this Privacy & Cookie Policy, is the controller and responsible for your personal data  

Our Data Protection Officer is Jo Cunningham.  Jo is responsible for overseeing any requests relating to this Privacy Policy, and for dealing with any requests relating to your data protection rights.  Jo can be contacted by email at [email protected].

3. Third party links

Our Site 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.

4. What Is Personal Data?

Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.  It does not include data where the identity has been removed (anonymous data).

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy & Cookie Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 16.

b) The right to access the personal data we hold about you. Part 14 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 16 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 16 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 16.

6. If you have any cause for complaint about our use of your personal data, we would welcome an opportunity to resolve this with you: please contact us using the details in Part 16.  If you are not happy with how we have attempted to resolve your complaint, you may contact the Information Commissioner’s Office, 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.

7. What Data Do You Collect and How?

Depending upon whether you are simply using Our Site or are a Client, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.  Please also see Part 15 for more information about our use of Cookies and similar technologies.  With the exception of medical information and information relating to your health, sexual orientation, gender identity and / or religious beliefs referred to below, we do not collect any ‘special category’ or ‘sensitive’ personal data or data relating to criminal convictions and/or offences.  We only collect personal data relating to children if you are engaging our paediatric dietitian.

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 into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service contract you have with us but we will notify you if this is the case at the time. 

Data Collected

How We Collect the Data

Identity Information including name, age and date of birth.

Our client registration form, website booking form and any written communications you may send to us including electronic communications.

Contact information including address, email address, telephone number and emergency contact number.

Our client registration form, website booking form and any written communications you may send to us including electronic communications.

Your current medical condition and past medical history and (if required by your insurer) sexual orientation or gender identity 

Our client registration form, website booking form, any consultations we may conduct with you, any information provided to us by other medical or healthcare professionals at your request, together with any oral or written communications you may have with us including electronic communications.

Your diet history and (if relevant to your eating patterns or requirements) your religious beliefs

Our client registration form, website booking form, any consultations we may conduct with you, together with any oral or written communications you may have with us including electronic communications.

Your GP’s name and contact details.

Our client registration form and any oral or written communications you may have with us including electronic communications.

Payment information including your purchase history from us.

Our billing process.

User profile information including your interests and your marketing and communications preferences

Our GDPR consent form, website booking form and any written communications you may send to us including electronic communications.

Technical information including your IP address, login details, details about your browser, operating system, length of visit to pages on Our Site, page views and navigation paths, the number of times you use Our Site, time zones and other technology on the devices you use to access Our Site.

Analytics systems provided by Google or similar services, our security software and any written communications you may send to us including electronic communications.

Other people’s personal data, including next of kin name and contact details and (if you are a Client receiving health psychology services) names of individuals in your support network.

Our client registration form and any oral or written or communications you may have with us including electronic communications.

8. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. 

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.
  • Where you have consented to us using or processing your personal data, either by completing our GDPR consent form or by consenting to receiving direct marketing communications from us. You have the right to withdraw consent at any time by contacting us.

The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do

What Data We Use (as set out above)

Our Lawful Basis

Processing communication data

Identity and contact information supplied by you 

Our legitimate interest in communicating with you, keeping records and pursuing or defending legal claims.

Providing and managing your access to Our Site.

Identity and contact information supplied by you, your user profile and technical information.

Our legitimate interests in properly administering Our Site and our business, defining our client base and ensuring relevant content is provided to you, to keep Our Site updated and relevant and ensuring the security of Our Site; to maintain back-ups of Our Site and/ or databases and to enable publication and administration of Our Site.

Administering our business

Identity and contact information supplied by you, your payment information and technical data. 

Our legitimate interest in properly administering our business and performing our contracts, including developing our business and informing our marketing strategy, troubleshooting, data analysis, testing, systems maintenance and reporting.

Supplying our services to you, including managing appointments, providing clinical services and liaising with other medical providers and/ or insurers with your consent

Identity and contact information for you, your next of kin or support network, information regarding your medical condition and history and/ or diet, information regarding your preferences, information regarding billing and payment, user preferences.

Our legitimate interest in entering into and performing our contract to provide you with access to dietitian and/ or health psychologist or related services; including processing the data to enter into the contract and supply the services you have purchased under that contract, and keeping records of those transactions.  In the case of information regarding your medical condition, medical history and diet, we also collect, use and process this information with your consent, which is given when you sign our GDPR consent form, in order to provide your care and to comply with our medical legal obligations.

Managing payments for our services.

Identity, contact and billing information.

Our legitimate interests in collecting payment for the services we supply and thereby protecting and growing our business.

To handle your queries and obtain your feedback

Depending on the nature of your query or feedback, we may use your identity, contact, payment, and/or special category data to respond or investigate. 

Our legitimate interests in managing our business, performing the contract between us, and/or provision of care.

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity and contact information and information regarding your purchase history and preferences

Our legitimate interests  in developing our products and services and growing our business.

We may use your identity, contact, technical, user 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 refer to this as marketing). 

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

We will get your express 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 messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

We use a third-party payment processors, currently Stripe, GoCardless and PayPal, (“Payment Processors”) to assist in securely processing your payment information. If you pay with a credit card the payment information that you provide is encrypted and transmitted directly to the Payment Processor. We do not store your payment information and do not control and are not responsible for the Payment Processors or their collection or use of your information. You may find out more about how the Payment Processors store and use your Payment Information by accessing the Payment Processors’ privacy policies here: Stripe; GoCardless.

If you choose to use PayPal to make payment for our services, you will be directed to the PayPal website and provide your payment information directly to PayPal. PayPal’s privacy statement applies to the information you provide on the PayPal website.

We do not carry out automated decision making or any type of automated profiling. 

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. 

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

9. How Long Will You Keep My Personal Data?

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected (including for the purposes of providing our services to you, or of satisfying any legal, accounting or reporting requirements).  

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means, and the legal 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.

For tax purposes, the law requires us to keep basic information about our customers (including identity, contact and payment information as well as information on the contracts we enter into with our clients) for six years after they stop being clients.

In some circumstances, we may anonymise your personal data for research of statistical purposes in which case we may use this information indefinitely without further notice to you.

10. How and Where Do You Store or Transfer My Personal Data?

The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

  • agreed, organisation-wide standards on security and data handling;
  • personal data is stored on a secured network;
  • physical security controls at our clinic;
  • access to your personal data is limited to those employees, agents, contractors, and other third parties with a legitimate need to know and they are subject to duties of confidentiality; and
  • we have in place procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the relevant authorities where we are legally required to do so.

We may use external third parties to provide systems, technology or support which involves them processing personal data, necessitating a transfer of that personal data.  For example, our email system is provided by Google, our CRM sales system is provided by Pipedrive and our practice management system (WriteUpp) is provided by Pathway Software (UK) Limited.  Some external third parties, including Google and Pipedrive, may use physical or cloud storage which is based outside the United Kingdom.  By providing any information, including personal data to us, you consent to such transfer, storage and processing.  

Countries outside the EEA may not have data protection laws that are as strong as those in the UK. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, by using contracts with external third parties that require the same levels of personal data protection that would apply under the Data Protection Legislation. 

We may also need to share or transfer your data to a third-party healthcare provider outside the United Kingdom if you are a resident of another country and that third party healthcare provider is providing your ongoing care and you have specifically requested us to share that data.

11. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

  • We may have to share your personal data with service providers who provide IT and system administration services.  For example, we use: 
    • Pipedrive to provide our CRM sales system.  This data processing addendum describes how Pipedrive processes our clients’ data.
    • WriteUpp, provided by Pathway Software (UK) Limited, to provide our practice management system.  See Pathway Software’s Privacy Policy, which sets out how it processes our clients’ data.
  • We may also share your personal data with your referrer, the NHS or other independent healthcare professionals or your health insurers, or with other third parties (such as courier services who deliver tests to our clients) if you specifically request this and have consented to it.
  • We may be required to share personal data (for example with your GP or with the emergency services) if we consider that there is a real risk of harm to you or to others.
  • On occasion we may also share your personal data with our professional advisers such as lawyers, bankers, auditors and insurers.  
  • We may need to share your personal data with HM Revenue & Customs, regulators and other authorities based in the United Kingdom if they request this.
  • We may use a third-party provider of email direct marketing services, in which case we will share your personal data with them for the purpose of providing those direct marketing services only, provided you have opted-in to receive our marketing communications.
  • If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy & Cookie Policy.
  • In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if:
    • we are involved in legal proceedings
    • we are complying with legal obligations, for example as regards our safeguarding obligations, or our obligations in relation to terrorism, money laundering or drug trafficking
    • we are complying with a court order
    • we are complying with the instructions of a government authority
    • we are required to do so by a regulatory body, for example in relation to a client complaint or regulatory breach or investigation.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 10.  

If any personal data is transferred outside of the United Kingdom, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom and under the Data Protection Legislation, as explained above in Part 10.

12. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data.  We aim to give you control over our use of your data for direct marketing purposes (including the ability to opt out of receiving marketing emails from us), which you may do by unsubscribing using the links provided. 

13. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 15 below.

14. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 16. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

15. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than usThird-party Cookies are used on Our Site for the purposes of our analytics system.  These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up asking you to give your consent to set those Cookies.  By consenting to the placing of Cookies you are enabling us to provide the best possible experience and service to you.  

Our Site uses Google Analytics and Droptrim to provide website analytics services. Website analytics refers to a set of tools used to collect and analyse usage information, enabling us to better understand how Our Site is used and how best to target potential customers. This, in turn, enables us to improve Our Site and the services offered through it.  

Our Site also uses third party cookies from social media sites such as Facebook and Instagram, which allow us to measure the effectiveness of our social media advertising campaigns by tagging social media users when they visit Our Site, and to re-target our advertising.

These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.  

The above services used by Our Site use third-party Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.

16. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email our DPO at [email protected] ,  marking your email “Subject Access Request”.

18. Changes to this Privacy Policy and your duty to inform us of changes of changes to your personal data

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.

We may change this Privacy & Cookie Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy & Cookie Policy on your first use of Our Site following the alterations.  We recommend that you check this page regularly to keep up-to-date. This Privacy & Cookie Policy was last updated on 20 April 2022.

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