Privacy Policy

  1. 1. Introduction

    Goodness Clementine Nutrition is committed to protecting and respecting your privacy. We want you to understand what information is being collected and why. This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.goodnessclementinenutrition.com.

    This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail - we are happy to provide any additional information or explanation needed. Any requests for this should be sent to [email protected]. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2023.

    By providing us with your data, you warrant to us that you are over 18 years of age. 

    Goodness Clementine Nutrition is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

    Our full contact details are:

    Full name: Goodness Clementine Nutrition

    Email address: [email protected]

    Address: 17 West Terrace, Penarth, Vale of Glamorgan CF64 2TX

    If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

    It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]

    2. What we do

    Goodness Clementine 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. We also provide workshops and group programmes.

    3. How we obtain your personal data

    We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy below for more details about this.  We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

    We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

    Information provided by you

    You provide us with personal data 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/messaging service, or by post
    • By taking credit card and online payment

    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
    • Credit/bank card 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.

    Following completion of your healthcare we retain your personal data for the period defined by our professional association BANT and registrant body, 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.

    Information we get from other sources

    We may 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 your personal data is for legitimate interest.

    We may 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.

    4. What data do we collect about you, for what purpose and on what ground do we process it?

    We act as a data controller for use of your personal data to provide direct healthcare. 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.

    We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.

    We may use your personal data where there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime. Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters (see below) but this would be subject to you giving us your express consent. 

    Personal data means any information capable of identifying an individual. It does not include anonymised data.

    We may process the following categories of personal data about you:

    Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

    Client Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

    User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

    Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

    Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

    We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

    Sensitive Data refers to data that includes:

    • 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
    • Credit/bank card details

    We do not intend to collect any information about criminal convictions and offences, details about your religious or philosophical beliefs, political opinions, trade union membership.

    Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

    We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected].
    In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

    We may process your personal data without your knowledge or consent where this is required or permitted by law. 

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

    5. Marketing Communications

    Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

    Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

    Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

    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 emailing us at [email protected] at any time.

    If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions or consultations.

    6. Disclosures of your personal data

    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:

    • Our registrant body, CNHC, and our professional association, BANT, for the processing of a complaint made by you
    • 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
    • Any legal or crime prevention agencies and/or to satisfy any regulatory request (eg, 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. We will not include any sensitive information.

    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 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.

    We may have to share your personal data with other parties set out below:

    • Service providers who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers
    • Government bodies that require us to report processing activities.
    • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

    We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

    7. International Transfers

    We may need to share your personal data with a group of companies which involves transferring your data outside the European Economic Area (EEA), eg, our web-based booking platform or supplement companies.

    Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

    Many of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

    • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
    • Where we use certain service providers, 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
    • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

    If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

    8. Data Security

    We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

    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 encryption (which masks data so that unauthorised users cannot see or make sense of it). 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.

    We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

    We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

    Goodness Clementine Nutrition is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).

    9. Data Retention

    All records held by Goodness Clementine Nutrition will be kept for the duration specified by guidance from our professional association BANT.

    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, as specified by BANT.

    For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

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

    10. Your Legal Rights

    Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent, with some exceptions. You do not need to give a reason to see your data.

    If you want to access your data you must make a subject access request in writing to [email protected]. Under special circumstances, some information may be withheld. We shall endeavour to respond within 20 working days from the point of receiving the request and all necessary information from 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

    You have the right, subject to exemptions, to ask to:

    • Have your information deleted
    • Have your information corrected or updated where it is no longer accurate
    • Ask us to stop processing information about you where we are not required to do so by law or in accordance with the BANT and CNHC guidelines.
    • Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
    • Object at any time to the processing of personal data concerning you

    We do not carry out any automated processing, which may lead to automated decision based on your personal data.

    If you would like to invoke any of the above rights then please write to the Data Controller at 17 West Terrace, Penarth, Vale of Glamorgan, CF64 2TX or email [email protected].

    You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

    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 or refuse to comply with your request in these circumstances.

    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.

    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

    If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

    11. Third-Party Links

    Our 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 notice of every website you visit.

    12. Cookie Policy

    Our site uses cookies. Cookies are small data files that assign you a unique identifier. The collection of this information permits us to administer our site more efficiently and to provide a more tailored and user-friendly service to you. You may set your browser to prevent cookies from being sent; if you do so, this may limit the functionality of our site.

    We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.

    Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

    Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

    To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

    13. Analytics

    Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

    14. Contact 

    If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at 17 West Terrace, Penarth, Vale of Glamorgan, CF64 2TX or email [email protected] and we will do our best to help you.

    If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.

    Should you have questions regarding this Privacy Policy, please contact [email protected].

    Updated: January 2023