This Policy applies as between you, the User of this Web Site and Freedom Wellness Therapy Limited (we, us, our, FWT, Freedom Wellness Therapy) the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
We collect personal data in the following ways:
You may provide personal data when you complete online forms, request/book a treatment, purchase a products/services, subscribe to our services, create a user account, join our mailing list or otherwise or correspond with us (by post, phone or email)
We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.
Publicly available sources
We may collect personal data from publicly availably sources
We may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising and social media networks such as Facebook, Twitter etc; and (c) search information in the EU; (d) our suppliers such as payment providers, delivery services, partners, website support and maintenance providers.
Schedule 1: Personal Data
Part 1: Types of personal data
Location address, billing address, delivery address, email address and telephone number
Bank account and payment card details
First name, maiden name, last name, username or similar identifier
Marketing and communication data
Your preferences in receiving marketing from us and our partners, third parties and your communication preferences
Your username and password, bookings and treatments completed, product purchases made by you, preferences, feedback and survey responses
Internet Irotocol (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 our website
Details about payments to and from you and other details of products and services you have purchased from us
Part 2: Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
You have given your express consent for us to process your personal data for a specific purpose
The processing is necessary for us to perform and deliver our Services to you
The processing is necessary for us to comply with legal or regulatory obligation.
The processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our Web Site. Before we process your personal data on this basis, we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
Type of data
Lawful basis for processing
To register you as a new customer
Identity & contact
To perform our contract and deliver our Service(s) to you
To process and deliver your order, manage payments, fees and charges and debt recovery
Identity, contact, financial, transaction and marketing & communications
(i) To perform our contract with you;
(ii) As necessary for our legitimate interest in recovering debts due to us.
Identity, contact, profile & marketing & communications
(i) To perform our contract with you
(ii) As necessary to comply with a legal obligation
(iii) As necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.
To administer and protect our business and this Web Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, contact & technical
(i) As necessary for our legitimate interests in 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
(ii) As necessary to comply with any legal obligations
To deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising
Identity, contact, profile, usage, marketing & communications & technical
As necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our Web Site, products/services, marketing, customer relationships and experiences
Technical & usage
As necessary for our legitimate interests to define types of customers for our products and 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 goods or services that may be of interest to you, including promotional offers
Identity, contact, technical, usage & profile
As necessary for our legitimate interests to develop our products/services and grow our business
Part 3: Your legal rights
You have the following legal rights in relation to your personal data:
Access your data
You can ask for access to and a copy of your personal data and can check we are lawfully processing it
You can ask us to correct any incomplete or inaccurate personal data we hold about you
You can ask us to delete or remove your personal data where:
(a) There is no good reason for us continuing to process it;
(b) You have successfully exercised your right to object (see below);
(c) We may have processed your information unlawfully; or
(d) We are required to erase your personal data to comply with local law.
(e) We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
You can object to the processing of your personal data where:
(a) Where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;
(b) Where we are processing your personal data for direct marketing purposes.
(c) In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your persona data for such purposes
You can ask us to us to suspend or restrict the processing of your personal data, if:
(a) You want us to establish the accuracy of your personal data;
(b) Our use of your personal data is unlawful, but you do not want us to erase it;
(c) You need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it
Request a transfer
You can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format
Withdraw your consent
You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent
Part 4: Third Parties
Acting as processors or controllers based in the EEA but also around the world who provide marketing services and IT and system administration services.
Independent Practitioners and Retailers
As independent treatment and product deliverers.
Acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services
HM Revenue & Customs, regulators and other authorities
Based in the EEA who require reporting of processing activities in certain circumstances
Part 5: Glossary
Information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject
A body that determines the purposes and means of processing personal data
An individual living person identified by personal data (which will generally be you)
Information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data
A body that is responsible for processing personal data on behalf of a controller
Special categories of personal data
Information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.
Information Commissioner’s Office, the UK’s supervisory authority for data protection issues