Privacy Policy

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site http://bulimiafree.com.

By providing us with your data, you warrant to us that you are over 13 years of age.

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

 

2. CONTACT DETAILS

If you need to contact us about anything related to this privacy policy, you can email us at Julie@BulimiaFree.com or you can write to us: Julie Kerr, t/a Bulimia Free, 11a Lymington Road, London, NW6 1 HX

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, for example you change your email address, by emailing us at Julie@BulimiaFree.com. From time to time we may email you to check that the personal data we hold for you is accurate and up to date.

 

3. WHAT DATA DO WE COLLECT ABOUT YOU

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

We may collect the following data about you:

  • Your name
  • Your email address
  • Your address
  • Your phone number
  • Your date of birth
  • Any personal data you post on our website
  • Data about how you use our website
  • Technical data 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.
  • Your marketing and communication preferences
  • Any other information that you directly provide us whether through the contact form, ‘Discovery Call’ questionnaire, over the phone, by email or otherwise, such as completing a survey or entering a competition.

 

4. HOW WE MAY USE YOUR DATA

We will use your data in order to:

  • Send you the free resources you have requested.
  • Send you marketing communications where we are allowed by law to do so.
  • Send you customer communications about enhancements to our services and products you have bought
  • Enable us to perform ‘Discovery Calls’ or a contract with you, to process orders, respond to enquiries related to the order and deal with any complaints.
  • Reply to any enquiries you make about our products of services
  • Keep records of orders placed and communications in relation to such orders
  • Keep records of communications
  • To respond to email requests for information and help
  • Ask you to complete surveys or invite you to enter into competitions or prize draws
  • Administer and protect our business and website
  • Analyse your use of our website and other online services
  • Personalize your experience of our website
  • Monitor the use of our website and online services
  • Deliver relevant website content and advertisements to you
  • Understanding the effectiveness of our advertising
  • Bring legal claims against you if you breach a contract or fail to make payment (we know you won’t)
  • Comply with any legal obligations we are subject to or as required by a government authority
  • Manage our business.

 

5. ON WHAT GROUND WE PROCESS YOUR DATA: OUR LAWFUL GROUND OF PROCESSING

Under the EU General Data Protection Regulations, we are only legally able to process your personal data if we have a lawful ground for doing so.

Our lawful grounds for processing are:

  • In relation to Customer Data that we have obtained in relation to you placing an order with us for our services and/or product that we hold for the purpose of fulfilling that contract, informing you of upgrades to the service and or/product and keeping records of the contract, the processing is necessary for the performance of the contract to which you are subject and for our legitimate interests in informing you about updates to the service and or product, record keeping and to establish, pursue or defend legal claim as responsible business operations. Data may include your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details but will be limited and relevant to your purchase.
  • In relation to Prospect Data that we have obtained when you enquired about our services or programs (whether that be through the website or otherwise) and that we process to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request to reply or prior to entering into a contract with you and for our legitimate interests in record keeping and to establish, pursue or defend legal claim.
  • In relation to Prospect Data that we have obtained when you signed up for any of our free resources and that we keep in order to send you those free resources, reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of sending you the resource and it is in our legitimate interest to reply to your communications and to keep records for our business.
  • In relation to 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.
  • In relation to Marketing Data that we have obtained from you when you told us of your marketing preferences, when you consented to us sending you details of our products and services, for the purpose of sending you non-marketing and marketing communications, enabling 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, the process, the processing is our legitimate interests which in this case are to study how customers use our services/products, to develop them, to grow our business and to decide our marketing strategy.
  • In relation to User Data that we have obtained through cookies on our website, together with any data that you post for publication on our website or through other online services, for the purposes of operating our website, ensuring relevant content is provided to you, ensuring the security of our website, maintaining 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, the processing is necessary for our legitimate interests which in this case are to properly administer our website and business.
  • In relation to 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, 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 website 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.
  • 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).
  • In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in providing a service and or product or responsible operations of defending, pursuing or establishing a claim.

 

6. SENSITIVE DATA

We do not collect any Sensitive Data about you that refers to or includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about your genetic and biometric data.

We do not collect any information about criminal convictions and offences.

However, we need to collect the following sensitive data about you in order to offer the most relevant advice in our Discovery Calls and to provide coaching and mentoring services and programs that get you the results you desire.

The SENSITIVE DATA REQUIRED is information about your health, well-being and lifestyle as it pertains to your struggle with an eating disorder and your recovery. That is, the data collected will be relevant and limited to what is necessary for the provision of service requested or contracted.

Our lawful ground for this processing is legitimate interests to enable us to offer the most relevant advice in our Discovery Calls and for the provision of service in our coaching and mentoring services and programs.

We require your explicit consent for processing sensitive data, so when you submit you The Discovery Call Questionnaire, we will send you a further communication asking for you to confirm your consent to this processing. You do not have to complete the questionnaire to have a Discovery Call.

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 services and or products to you). If you don’t provide us with the requested data, we may have to cancel a service and or product 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 Julie@BulimiaFree.com.

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.

 

7. HOW WE COLLECT 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 for more details about this http://bulimiafree.com/cookie-policy/

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.

 

8. 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 emailing us at Julie@BulimiaFree.com. We also have ‘unsubscribe’ buttons on the bottom of all our emails.

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, warranty registrations etc.

 

9. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the 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.

 

10. INTERNATIONAL TRANSFERS

To successful run our business and provide you with the free resources and relevant information and to provide our services and programs it is necessary to transfer your personal data outside the European Economic Area (EEA) to our third parties service providers.

Being subject to the provisions of the General Data Protection Regulations that protect persona data, where we transfer your data to third parties outside the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

  • 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
  • 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; or
  • Where we use certain service providers, who are established outside the EEA, 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.

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.

 

11. DATA SECURITY

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.

 

12. DATA RETENTION

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.

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 legal requirements.

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.

 

13. 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.

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

If you wish to exercise any of the rights set out above, please email us at Julie@BulimiaFree.com

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.

 

14. 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 notice of every website you visit.

 

15. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see http://bulimiafree.com/cookie-policy/

 

Effective From 25/05/2018