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Introduction
Harley Street Wellness Foundation is committed to safeguarding your privacy. Contact us at info@hswf.org.uk if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
By using this site or/and our services, you consent to the processing of your Personal Data as described in this Privacy Policy.
This privacy policy provides you with details about how we collect and process your personal data through your use of our website www.hswf.org.uk.
By providing us with your data, you warrant to us that you are over 16 years of age.
Ronny Sandhu, trading as Harley Street Wellness Foundation, is the data controller and is responsible for your personal data (referred to as “We”, “us” or “our” in this privacy policy).
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Third-party links
- Contact information
Definitions
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being processed.
Child – a natural person under 16 years of age.
We/us (either capitalised or not) – Harley Street Wellness Foundation
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our processing activities have lawful grounds. We always consider your rights before processing Personal Data. We will provide you information regarding processing upon request.
- Processing is limited to the purpose. Our processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated processing – meaning you have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for processing of your Personal Data.
Data we gather
We do not collect any Special Category Data about you. Special Category Data is Data such as your race, ethnic origin, religion, health information and sexual orientation.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
We do not carry out automated decision making or any type of automated profiling.
We may process your Personal Data without your knowledge or consent if we are legally obliged to do so.
The types of Data we gather is as follows:
Communication Data
Communication Data includes any communications you send to us (i.e. through a contact form on our website, by email, text, social media or any other communication that you send to us). Data processed might include your e-mail address, name, postal address etc – mainly information that is necessary for communicating with you or to enhance your customer experience with us.
Technical Data
Technical Data includes Data about your use of our website such as your IP address, details about your browser, the type of device you use to access our website, your login history, length of visit to pages on our website, etc. We gather this Data from Google Analytics and from our security software. Technical Data also includes information that is automatically stored by cookies and other session tools. When you use our services or look at the contents of our website, your activities may be logged.
Security Logs
The IP address of visitors, user ID of logged in users, and username of login attempts are conditionally logged to check for malicious activity and to protect the site from specific kinds of attacks. Examples of conditions when logging occurs include login attempts, log out requests, requests for suspicious URLs, changes to site content, and password updates. This information is retained for 14 days.
User Data
User Data includes Data about how you use our website, together with any Data that you post for publication on our website in the form of a comment or review.
Comment Data
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available at https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media Data
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Data from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.
Publicly available Data
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- Provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- Enhance your customer experience.
- Fulfil an obligation under law or contract.
We use your Personal Data on legitimate lawful grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we process your Personal Data for the following purposes:
- To identify you.
- To provide you a service or to send/offer you a product.
- To communicate either for sales or invoicing.
On the ground of legitimate interest, we process your Personal Data for the following purposes:
- To reply to communications sent to us.
- To send you personalised offers.
- To administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided.
- To enable us to properly administer our website and our foundation.
- To grow our foundation.
- To conduct questionnaires concerning client satisfaction.
- To keep records.
- To help us to decide our marketing strategy.
- To establish, pursue or defend legal claims.
As long as you have not informed us otherwise, we consider offering you products or services that are similar to or the same as your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we process your Personal Data for the following purposes:
- To send you newsletters and campaign offers.
- For other purposes we have asked your consent for.
We process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We won’t retain your Personal Data for longer than necessary to fulfil the purpose(s) we collected it for. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 6 years.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- The link between purposes, context and nature of Personal Data is suitable for further processing;
- The further processing would not harm your interests; and
- There would be appropriate safeguard for processing.
We will inform you of any further processing and purposes.
We will never share your Personal Data with any third party for their own marketing purposes.
You can unsubscribe from our marketing communications at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@hswf.org.uk.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases etc.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience.
Some of our third party service providers are based outside of the EEA (in the US for example) so on some occasions, your Personal Data is transferred outside of the EEA in order to be processed.
Whenever we transfer your Personal Data out of the EEA, we ensure at least one of the following safeguards is in place:
- We only transfer your Personal Data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- We may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- We use US-based providers that are part of EU-US Privacy Shield
Who we share your Data with
Our processing partners:
- Giraffical – as our website developer and website host. Their Privacy Policy can be found at https://giraffical.co.uk/privacy-policy/.
- Mailchimp – as our email marketing software provider. Their Privacy Policy can be found at https://mailchimp.com/legal/privacy/.
- Dropbox – our cloud storage provider for website backups. Their Privacy Policy can be found at https://www.dropbox.com/en_GB/privacy.
- PayPal – our payment processing provider. Their Privacy Policy can be found at https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
- Just Giving – our causes partner. Their privacy policy can be found at https://www.justgiving.com/info/privacy-policy-versions/privacy-policy-v20.
We may also have to share your Personal Data with professional advisers such as solicitors, accountants, bankers or insurers; IT service providers; and Government bodies that require us to report processing activities.
A QR code image is generated for users that set up two-factor authentication for this site. This image is generated using Google Chart’s API. As part of generating this image, your username is sent to the API. For details about Google Chart’s privacy policy, please see Security and Privacy in Charts.
This site is scanned for potential malware and vulnerabilities by Sucuri’s SiteCheck. We do not send personal information to Sucuri; however, Sucuri could find personal information posted publicly (such as in comments) during their scan. For more details, please see Sucuri’s privacy policy.
This site is part of a network of sites that protect against distributed brute force attacks. To enable this protection, the IP address of visitors attempting to log into the site is shared with a service provided by ithemes.com. For privacy policy details, please see the iThemes Privacy Policy.
We only allow third parties to process your Personal Data for specified purposes in accordance with our instructions and we only work with processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe:
- We use safe protocols for communication and transferring data (such as HTTPS).
- We monitor our systems for possible vulnerabilities and attacks.
- We use a firewall.
- We use strong passwords for all accounts where Personal Data can be accessed.
- We use anonymising and pseudonymising where suitable.
- We use Dropbox to store backups of our website securely.
- Backup zip files are stored with hashed file names to prevent filename guessing and directory browsing is disabled.
Even though we try our best, we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
Cookies and other technologies we use
We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
For further information about Cookies and how we use them, please review our Cookie Policy.
Third-party links
This website may include links to third-party plug-ins, websites and applications. By clicking on those links or enabling those connections, you 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, please do read the privacy policy of the websites you visit.
In addition to this, articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Contact Information
Our contact details
Full name of legal entity: Ronny Sandhu trading as Harley Street Wellness Foundation
Email address: info@hswf.org.uk
Supervisory Authority
ICO – ico.org
Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy.
Last modification was made 1st June 2018.