Privacy and Cookie Policies

Welcome to our privacy policy. Healthy Minds Club Limited (HMC) in partnership with Shirley Rose is committed to protecting your privacy. We will only use the information that we collect about you lawfully (in accordance with the Data Protection Act 2018). 

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how HMC collects and processes your personal data through your use of this website, including any data you may provide through this website when you use our online services to use your digital gift code or communicate with our customer services team.

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 policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.

CONTROLLER  

HMC is the controller and responsible for your personal data (collectively referred to as ”HMC”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (our “DPO”) 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 protection officer using the details set out below.

CONTACT DETAILS  

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Healthy Minds Club Limited. 

Email address: hello@healthymindsclub.com

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 18th February 2021.

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.

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, last name, title.

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

Financial Data includes payment card details.

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

Technical Data includes internet protocol (IP) address, 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 bookings made by you, your interests, preferences, feedback and survey responses.

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

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

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.

The only Special Categories of Personal Data we collect about you are the details you provide about your mental health when you complete our questionnaire to determine the expert service you require.

IF YOU FAIL TO PROVIDE PERSONAL DATA  

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 any other services). In this case, we may have to terminate your access to our services but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED? 

We use different methods to collect data from and about you including through:

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

Make a booking with an expert;

subscribe to any of our services or publications;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us feedback or contact us.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will never send you marketing material from any party without your prior opt-in consent. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy below for further details.

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

Technical Data from the following parties:

(a) analytics providers [such as Google based outside the EU];

(b)  advertising networks and

(c)  search information providers

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 obligation.

See the Glossary 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 although we will never send you marketing material from any party without your prior opt-in consent. You have the right to withdraw consent to marketing at any time by contacting us.

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 process your booking with an expert

(a) Contact

(b) Financial Data

Performance of a contract with you

To deliver our services including:

(a) Booking with one of experts

(b) Collect and recover money owed 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

(c) To respond to complaints and/or legal claims

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

Performance of a contract with you

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

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

(a) Identity

(b) Contact

(c) Technical

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)

(a) 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 products/services, to develop them, to grow our business and to inform our marketing strategy)

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

(a) Technical

(b) Usage

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

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

When you book and pay for a session with one of our experts we'll ask if you'd like to be contacted about new HMC features, offers and tips about your product. If you tell us you're happy to be contacted, we'll send you information about things you might be interested in via email or SMS.

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 products, services and offers may be relevant for you (we call this marketing).

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT  

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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA  

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

Internal Third Parties as set out in the [Glossary].

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. 

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 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.

DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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.

We will 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 [your legal rights] below for further information.

In some circumstances we will 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.

YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below 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 our DPO via the means set out in Contact Details above.

NO FEE 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 could 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 could 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.

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/product and the best 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.

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

THIRD PARTIES  

INTERNAL THIRD PARTIES  

None.

EXTERNAL THIRD PARTIES  

Clearview Internet Solutions acting as processors based in the UK who provide IT and system administration services.

Our selected panel of experts with whom you have made a booking.

Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK 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 continuing 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 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:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

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.

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

Our Use Of Cookies

We use "cookies" to store and collect information regarding your usage of our website. These cookies do not contain any personally identifying information, but they do enable us to put in place personal settings and load your personal preferences. This makes it a better experience for you.

What are cookies?

Cookies are tiny files which websites use in order to work properly and provide important visitor data to website owners. They can be placed on your computer when you visit a website and help to make your web experience quicker, easier and tailored to you.

Session cookies are those which expire upon the closing of the web browser and persistent cookies are those which remain in place after a session has ended.

There are four key types of cookie:

Essential Cookies:

Without essential cookies, websites will not work properly. Essential cookies allow you to move around a website and complete basic functions, such as adding items to your shopping basket or going through the checkout process to make a purchase.

They enable:

• E-commerce checkout and basket functionality
• Login/registration
• Device targeting - showing users the correct site depending on which device they are using e.g. mobile or PC.

Analytics Cookies:

Analytics cookies allow website owners to gain an understanding of their traffic and visitor engagement levels, with this they can continually improve their website and better the user experience.

They can tell us:

• Where visitors are coming from (e.g. via search engines, referred from other sites or direct visits)
• Which pages they view
• How long visitors spend on the website
• How many visitors convert (make an enquiry/purchase/place an order etc.)

Preference Cookies:

Setting cookies allow websites to improve user experience and remember the site preferences for returning visitors and users.

Examples include:

• Font size and style
• Page layout e.g. colours and layout styling
• Number of search results/posts/threads/news items to display per page
• Login settings

Marketing Cookies:

Marketing cookies allow for improved advert targeting, ensuring that you get to see ads for things which are the most relevant to you.

How can I disable cookies?

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the The Healthy Minds Club services or Web sites you visit.

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 

Click here to change your cookie settings
on the Healthy Minds Club Website

DIFFERENT TYPES OF COOKIES

Cookies used across the The Healthy Minds Club website fall into the following categories.

Cookie Type	Description
Essential	Cookies that are necessary to carry out or facilitate the web service you are looking for.
Analytics	Cookies that collect information about how visitors access & use the The Healthy Minds Club website. The data collected is used to inform digital marketing performance & website design / performance improvements.

 

COOKIES USED ON OUR SITE

Essential

Purpose: These cookies are essential to allow you to navigate and use our website securely.
1st Party Cookies (unless specified)
Session Cookies	Persistent Cookies
ASP.NET_SessionId _RequestVerificationToken .DOTNETNUKE dnn_IsMobile language	.ASPXANONYMOUS consent consent-analytics consent-essential consent-marketing consent-preferences

Measurements

Google Analytics
Purpose: Google Analytics allows us to measure Google Search usage and to analyse & optimise website landing pages and our visibility on search engines.
1st Party Cookies (unless specified)
Data Retention Period: a minimum of upto 24 months
Session Cookies	Persistent Cookies
	_ga _gid _gat _gac_XXXXXXXX

More cookie info

Information Commissioner's Office http://www.ico.gov.uk/cookies

Help info from Google about Cookies http://www.google.co.uk/goodtoknow/data-on-the-web/cookies/

Simple information about cookies http://www.aboutcookies.org/

Detailed information about cookies http://www.allaboutcookies.org/

 

© 2021 Healthy Minds Club Limited.