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Privacy Policy

Last updated [DATE YOU PUBLISH] · Version 1.0

The short version

  • Who I am. Healthier Sapiens Ltd. We decide how your data is used, which makes us the "controller" in legal terms.
  • What I collect. What you type into the application form, what you tell me during coaching, and anonymous statistics about how the website is used.
  • Why. To decide whether I can help you, to coach you if we work together, and to keep the site working.
  • Who sees it. Me. Plus the companies whose software I use to run the business, listed in section 6. I never sell your data and never share it for anyone else's marketing.
  • Your rights. You can ask for a copy, ask me to correct it, or ask me to delete it. Email hello@healthiersapiens.com and I'll deal with it within a month.

Contents

  1. Who I am and how to reach me
  2. The personal data I collect
  3. How I collect it
  4. How I use it, and my lawful basis
  5. Health information
  6. Who I share it with
  7. Transfers outside the UK
  8. Security
  9. How long I keep it
  10. Your legal rights
  11. Cookies and analytics
  12. Other websites
  13. Complaints
  14. Changes to this policy

1. Who I am and how to reach me

This website is run by Healthier Sapiens Ltd, a company registered in England and Wales under company number 15054823, with its registered office at 86-90 Paul Street, London, England, EC2A 4NE ("I", "me", "my").

I am the controller of the personal data described in this policy. That means I decide what is collected and what happens to it, and I am responsible for looking after it.

I am not required to appoint a Data Protection Officer, so any question about your data comes to me directly.

  • Email: hello@healthiersapiens.com
  • Post: Healthier Sapiens Ltd, 86-90 Paul Street, London, England, EC2A 4NE
  • ICO registration number: [ADD ONCE REGISTERED - or delete this line]

This policy covers the website at www.healthiersapiens.com and the coaching services provided through it. It does not cover other websites you might reach through links here.

2. The personal data I collect

Personal data means any information from which you can be identified. I group it as follows.

  • Identity and contact data - your name, email address and telephone number.
  • Application data - the answers you give on the application form: your goal, how long you have been working on it, whether you currently train, what you have already tried, what has got in the way, when you would like to start, which programme interests you, and anything else you choose to add in the free-text box.
  • Coaching data - if we work together, the information we exchange while coaching. This includes food, training, sleep, weight and measurements, how you are getting on, and anything you send me in messages or on calls. Some of this is health information, which is treated separately in section 5.
  • Transaction data - records of payments you have made for coaching. I do not receive or store your card details; those are handled by Stripe and, for payment plans, GoCardless.
  • Technical data - the IP address your application was submitted from, which I keep as a security and anti-spam measure.
  • Website usage data - anonymous statistics about how visitors use the site: pages viewed, how they arrived, rough country, browser and device type. This is described in section 11.

I do not knowingly collect data about children, and my services are for adults only.

The application form asks you not to include detailed medical information. That is deliberate. If health details are relevant, we cover them properly once we are working together, under the arrangements in section 5.

3. How I collect it

  • You give it to me - by filling in the application form, emailing me, messaging me, or talking to me on a call.
  • Automatically - anonymous usage statistics are collected as you browse the site, and your IP address is recorded when you submit an application.
  • From third parties - if you book a call, my booking provider passes me the time you chose and the contact details you entered.

4. How I use it, and my lawful basis

Under UK data protection law I need a lawful basis for everything I do with your data. Here is each purpose and the basis I rely on.

What I doData usedLawful basis
Read your application and decide whether I can help Identity, contact, application Consent, which you give by ticking the box on the form. You can withdraw it at any time.
Reply to you, and arrange and hold a call Identity, contact, application Consent, and where you go on to become a client, steps taken at your request before entering a contract.
Deliver coaching if we work together Identity, contact, coaching, transaction Performance of our contract.
Take payment and keep accounting records Identity, contact, transaction Performance of our contract, and legal obligation for tax and accounting records.
Keep the website working, secure and free of spam Technical, usage Legitimate interests - running a secure website and understanding whether it is useful.
Keep records in case of a complaint or claim Identity, contact, coaching, transaction Legitimate interests - being able to defend or resolve a claim, and legal obligation where a professional body or insurer requires records to be kept.

Marketing

I only send marketing emails to people who have asked to receive them. Applying for coaching does not sign you up to anything - if you apply and we do not work together, you will not be added to a list.

Where I do send them, I rely on your consent, given by opting in. Every message includes a one-click unsubscribe link, and you can also stop them at any time by emailing hello@healthiersapiens.com. Withdrawing consent for marketing does not affect anything else in this policy.

I never share your details so that another organisation can market to you.

If you don't provide the data

The application form needs your name, email and phone number. Without those I cannot reply to you, so I would not be able to consider your application.

5. Health information

Health data is what the law calls a "special category" of personal data, and it gets extra protection. Coaching you properly may involve it - what you eat, how you sleep, your weight, your energy, sometimes blood test results you choose to share with me.

I only process health information where you have given me your explicit consent to do so, which I will ask for separately at the point we start working together, and which you can withdraw at any time.

Two things worth being clear about:

  • I am a nutritional therapist and personal trainer, registered with the Association of Naturopathic Practitioners (ANP) and CIMSPA. I am not a doctor. I do not diagnose or treat medical conditions, and I work alongside your GP or consultant rather than instead of them.
  • My professional bodies and my insurer require client records to be kept for a set period, which is why coaching records are held for seven years even after we stop working together.
  • I ask you not to put detailed medical information into the website application form. If it is relevant, we handle it properly once we are working together.

6. Who I share it with

I do not sell your personal data, and I never share it so that another organisation can market to you.

I do use software to run the business, and those providers process data on my behalf under contracts that require them to keep it secure and use it only on my instructions. They are:

  • Hostinger - hosts this website and my email. Your application is stored on that server and emailed to me.
  • Umami - website analytics. Cookieless and anonymised; see section 11.
  • KIS CRM (built on GoHighLevel) - the booking system used to schedule calls, and where client records are kept.
  • WhatsApp (Meta) - used for messaging between coaching calls, if you choose to use it.
  • Zoom - used to hold coaching calls.
  • Stripe and GoCardless - take payment. They receive your name, email and payment details directly; I never see your card number.

I may also disclose personal data if I am required to by law, by a court, or by a regulator.

7. Transfers outside the UK

Some of the providers above store or process data outside the UK, including in the United States. That applies in particular to GoHighLevel, Zoom, Stripe and Meta.

Where data leaves the UK, the transfer is covered by one of the safeguards UK law allows - either an adequacy decision by the UK government, or the UK International Data Transfer Agreement or Addendum to the EU standard contractual clauses, together with any additional measures needed.

If you would like details of the safeguards used by a particular provider, email me and I will tell you.

8. Security

The measures in place include:

  • The website is served over HTTPS, so anything you type into the application form is encrypted in transit.
  • Applications are stored outside the public area of the web server, so they cannot be reached from the internet.
  • Access is limited to me. Accounts are protected by strong, unique passwords.
  • The form has anti-spam and rate-limiting measures to reduce abuse.

No system is perfectly secure, but if a breach happens that is likely to put your rights or freedoms at risk, I will tell you and the Information Commissioner's Office as the law requires.

9. How long I keep it

I keep personal data only as long as I need it for the purpose it was collected for.

WhatHow long
Applications where we don't go on to work together12 months, then deleted
Client records, including coaching and health data7 years after our last contact, in line with the requirements of my professional bodies and insurer
Accounting and tax records6 years after the end of the relevant tax year, as HMRC requires
Website analyticsAnonymous, and retained for 6 months by the analytics provider
Marketing consent recordsFor as long as you are subscribed, plus 2 years, so I can show consent was given

You can ask me to delete your data sooner - see section 10.

10. Your legal rights

Under UK data protection law you have the right to:

  • Get a copy of the personal data I hold about you.
  • Have it corrected if it is wrong or incomplete.
  • Have it deleted where there is no good reason for me to keep it.
  • Object to my using it where I am relying on legitimate interests.
  • Restrict what I do with it while a question about it is resolved.
  • Receive it in a portable format, or have it sent to another provider, where the processing is based on consent or a contract and is carried out automatically.
  • Withdraw consent at any time, where consent is the basis I am relying on. That does not affect anything done before you withdrew it, but it may mean I can no longer provide the service.

To exercise any of these, email hello@healthiersapiens.com.

There is no fee. I may ask you for information to confirm who you are, so that data is not given to the wrong person. I will respond within one month. If a request is unusually complex I may need longer, and I will tell you if so.

11. Cookies and analytics

This website does not use cookies for tracking, advertising or analytics. There is no cookie banner because there is nothing to consent to.

I use Umami, a privacy-focused analytics tool, to see how many people visit and which pages they read. It does not use cookies, does not follow you across other websites, and does not collect anything that identifies you. It records the page visited, the site you arrived from, and a rough country, browser and device type.

Some pages embed videos hosted on YouTube. Those videos do not load until you tap play. If you do play one, YouTube may set its own cookies and collect data under Google's privacy policy, which is outside my control.

12. Other websites

This site links to other websites, including my booking system and social media profiles. I am not responsible for their privacy practices, and I would encourage you to read their own policies.

13. Complaints

If you are unhappy with how I have handled your data, please tell me first at hello@healthiersapiens.com and I will try to put it right.

You also have the right to complain to the Information Commissioner's Office, the UK regulator for data protection:

  • Website: ico.org.uk/make-a-complaint
  • Helpline: 0303 123 1113
  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

I would be grateful for the chance to sort it out before you go to the ICO, but you are entitled to go to them directly.

14. Changes to this policy

If this policy changes, the new version will be posted here with an updated date at the top. Please keep me informed if your contact details change, so my records stay accurate.

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