Privacy policy

Privacy Policy

1. General

This privacy policy is about how the Freya Lifestyle Limited collects, processes, stores, and shares member’s data.

This Privacy Policy only relates to personal data collected by Freya Lifestyle Limited via the Freya Clinic website, application forms, emails, and telephone calls. Any personal data collected by Freya Lifestyle Limited is used in accordance with UK data protection legislation.

Users should be aware that if they access other websites, using the links provided, these are outside our control. If they provide personal data to other companies, the privacy policies of those companies determine the uses to which that information is put, and Freya Lifestyle Limited Privacy Policy will no longer apply.


2. The Data Protection Bill 2017

Freya Lifestyle Limited complies with the principles of the Data Protection Bill 2017 in accordance with General Data Protection Regulations (GDPR).


3. Purpose of data  

The data we collect from members is the data required to provide professional services to members, communicate with members and validate and verify the legitimacy of clients.  The data held by Freya Lifestyle Limited is collected at the time of application by members and includes name, surname, home address, email, phone number(s), intake form and case history.


4. What we do

Our business specialises in providing nutritional therapy services designed to enhance our clients' health through tailored diet and lifestyle interventions. We prioritise preventative healthcare, the optimisation of both physical and mental well-being, and management of chronic health conditions. By conducting nutritional therapy consultations, comprehensive dietary and lifestyle analyses, and biochemical testing, we strive to identify the root causes of your health concerns. Our goal is to address these issues with personalised dietary plans, nutraceutical prescriptions (supplements), and lifestyle recommendations. Additionally, we offer a range of other services, including educational seminars, recipe development, and product sales through our website. Angela Ferguson is the director of Freya Clinic and information client or otherwise is shared directly with the director.


5. How we obtain your personal data

You may be providing us with personal data in the following ways:

  • By completing a nutritional therapy intake form
  • By signing terms of engagement on the intake form
  • During a nutritional therapy consultation
  • Through email, over the telephone or by post
  • By taking credit card and online payment when purchasing products


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
  • Bank details

We use this information in order to provide you with direct healthcare. This means that the legal basis of us holding your personal data is for legitimate interest.

Following completion of your healthcare we retain your personal data for the period defined by our registrant body, ANP. This enables us to process any complaint you may make. In this case the legal basis of us holding your personal data is for contract administration.


6. 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.


7. How we use your personal data

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 and third-party fulfilment. 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 that 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, but this would be subject to you giving us your express consent. This is achieved through you signing up to our mailing lists via the website.

We may disclose your personal information (including to trusted third parties) for the purposes for which is primarily held or for a related secondary purpose and in some cases, we may disclose information without your consent. Your personal and sensitive information may be disclosed to Freya Lifestyle Limited representatives, service providers we use to deliver aspects of our service such as database or email software facilities.

Data is shared via member numbers with insurance providers for the purposes of verifying the legitimacy of insurance applicants.

Data is shared upon request on behalf of a member with external companies that provide practitioner services to verify qualification and status claims.

Data is shared with our regulator the General Naturopathic Council for the purposes of registering practitioners on a public register, and confirming their status as a fully qualified, voluntarily regulated practitioner.

Data is shared internally with administrators for the purpose of verifying payments and refunds.


8. Device specific data

The following information may be collected through your device and browser:

  • Your devices IP address (collected and stored in an anonymised format)
  •  Your email address including first name and surname
  • Device screen size
  •  Device type (unique identifiers) and browser information
  •  Geographic location (country only)
  • Preferred language used to display the webpage


9. Digital log data

Our servers automatically record information which is created using our software. Data includes:

  • Referring domain
  • Pages visited
  • Geographic location (country only)
  • Preferred language used to display information
  • Date and time when pages were accessed or created 


10. Consent

Freya Lifestyle Limited membership is an optional process. By joining Freya Lifestyle Limited, members consent via their application to receive information relating to the activities of Freya Lifestyle Limited in the form of newsletters, regulatory updates, upcoming seminars, webinars, events, training, special offers and information relevant to the profession. By providing personal data to Freya Lifestyle Limited users consent to the processing of such data by Freya Lifestyle Limited as described in this Privacy Policy. 


11. Opting out

Opt out mechanisms are in place on all Freya Lifestyle Limited mailings and communications. Users can choose to opt out at any time by clicking the opt-out button at the bottom of mailings or emailing Freya Lifestyle Limited directly with a request to opt out.


12. Verifying, updating and amending your personal information

If, at any time, a user wants to verify, update or amend their personal data they may write to:

Angela Ferguson

Freya Lifestyle Limited

angela@freyaclinic.co.uk

Verification, updating or amendment of personal data takes place within 10 working days. 


13. Storage of personal data

Data is stored in a secured, encrypted, cloud based database. Payments are processed according to the requirements of 12.9 PCI DSS v3.2 in accordance with PCI security standards.


14. Cookies

Freya Lifestyle Limited uses benign, short lived ‘session’ cookies to tell whether a website user has logged in, where to find details that can be used to pre-fill parts of on-line forms and to personalise the user’s visit to the website.

Freya Lifestyle Limited cookies do not analyse visits to other website, or any searches undertaken whilst on the Freya Lifestyle Limited website.

Internet browsers normally accept cookies by default; however, it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful session cookies. Choose an option that rejects all third party and long lived cookies.

Freya Lifestyle Limited uses cookie free technology that uses Internet Protocol (IP) information exchanged during the course of normal web activity combined with data enhancement technology to get detailed analytics information.


 15. Links to third party websites

This Privacy Policy applies solely to the personal data collected by Freya Lifestyle Limited and does not apply to third party websites.

Freya Lifestyle Limited is not responsible for the privacy policies of third-party websites. advises users to read the privacy policies of other websites before registering any personal data.


17. Security

Freya Lifestyle Limited holds your personal data in accordance with the security provisions of the UK data protection legislation.

If you have any questions about security, please contact Freya Lifestyle Limited on o 07902126500.


18. Notification of changes

Freya Lifestyle Limited will notify all users of any changes it makes to its Privacy Policy. If Freya Lifestyle Limited decides to change its Privacy Policy, it will post such changes on this page so that you are always aware of how Freya Lifestyle Limited uses your personal data.

Users have the right to ask Freya Lifestyle Limited, in writing, for a copy of all the personal data held about them upon payment of a fee (“subject access request”) and to request that Freya Lifestyle Limited correct any inaccuracies in that information.


19. Your rights over your data

You have the right to rectify, amend, correct or erase your data except where there is a legal basis for refusal.