Privacy policy

Privacy Policy

Freya Lifestyle Limited (“Freya Lifestyle Limited”, “Freya Clinic”, “we”, “us” or “our”) is committed to protecting your privacy and handling your personal data responsibly and transparently.

This Privacy Policy explains how we collect, use, store and share personal data when you interact with Freya Clinic, including when you visit or use our website, complete an application or intake form, purchase products or services, contact us by email or telephone, attend a consultation, or subscribe to our marketing communications.

We process personal data in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as well as applicable electronic marketing legislation including the Privacy and Electronic Communications Regulations (PECR).

For further information about the UK GDPR and data protection requirements, please refer to the Information Commissioner's Office.

1. Who we are

Freya Lifestyle Limited is the data controller responsible for your personal data covered by this Privacy Policy.

Freya Clinic specialises in nutritional therapy and functional health services designed to support clients through tailored dietary and lifestyle interventions. We provide nutritional therapy consultations, dietary and lifestyle assessments, biochemical testing, personalised nutrition and lifestyle recommendations, nutraceutical recommendations, educational resources, seminars, recipe development and products through our website.

Angela Ferguson is the Director of Freya Lifestyle Limited and is responsible for the management of client information.

If you have any questions about how we use your personal data, you can contact us using the details below:

Freya Lifestyle Limited
For the attention of Angela Ferguson
Email: angela@freyaclinic.co.uk
Telephone: 07902126500

2. What personal data we collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

Personal and contact information

Name and surname
Home or correspondence address
Email address
Telephone/mobile telephone number
Next of kin or emergency contact information where provided

Information relating to our services

Details of appointments and appointment requests
Referrals
Consultation notes
Dietary and lifestyle information
Health and wellbeing information
Medical history
Medication and supplement information
Biochemical and functional test results
Personalised health improvement plans
Information provided during nutritional therapy consultations

Health information is considered special category personal data under the UK GDPR and is subject to additional legal protections.

Transaction and payment information

Information relating to purchases of products and services
Payment and transaction information
Bank or payment information where required for processing transactions, refunds or other legitimate business purposes

We do not generally retain complete payment card details. Payment transactions are processed through appropriate payment providers.

Marketing information

If you choose to subscribe to our marketing communications, we may collect and process:

Your email address
Your mobile telephone number
Your marketing preferences
Your email and SMS subscription status
Information about your interactions with our marketing communications, such as whether an email has been opened or a link has been clicked, where applicable

Website and technical information

When you visit our website, we may collect technical information including:

IP address
Device type
Browser type
Screen size
Operating system or other device information
Pages visited
Referring website or domain
Date and time of website visits
General geographic information, such as country
Preferred language

Some of this information may be collected through cookies or similar technologies. Further information is provided in the Cookies section below.

3. How we collect your personal data

We may collect personal data directly from you when you:

Complete a nutritional therapy intake or application form
Agree to our terms of engagement
Attend a nutritional therapy consultation
Contact us by email, telephone or post
Purchase products or services through our website
Subscribe to our email marketing
Opt in to receive SMS marketing
Complete forms on our website
Communicate with us regarding an enquiry, appointment, purchase or service

We may also receive information from third parties, including biochemical and functional testing companies and, where you have provided appropriate consent, other healthcare providers.

4. How we use your personal data

We use personal data for the purposes for which it was collected and where there is a lawful basis for doing so.

These purposes may include:

Providing nutritional therapy and related professional services
Conducting consultations and assessments
Understanding your health history and current health concerns
Reviewing and interpreting biochemical and functional test results
Developing personalised dietary, nutritional and lifestyle recommendations
Managing appointments and communications
Processing purchases, payments, refunds and orders
Responding to enquiries
Managing our relationship with clients and customers
Maintaining appropriate professional and business records
Complying with legal, regulatory and professional obligations
Protecting the security of our website, systems and information
Sending marketing communications where you have provided the appropriate consent or where otherwise permitted by law
Improving our website, services and communications
Managing our business and legitimate administrative requirements

5. Lawful basis for processing your personal data

Under the UK GDPR, we must have a lawful basis for processing personal data.

Depending on the circumstances, we may process your personal data on the following bases:

Contract

We may process your personal data where this is necessary to provide products or services that you have requested, manage your relationship with us, fulfil an order or take steps at your request before entering into a contract.

Legitimate interests

We may process personal data where this is necessary for our legitimate business interests, provided that those interests are not overridden by your rights and interests.

Examples may include maintaining appropriate business records, managing our services, responding to enquiries, maintaining website security and administering our business.

Consent

Where required, we will ask for your consent before processing personal data for a particular purpose.

For example, we may request your consent to receive marketing communications by email or SMS.

You have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Legal obligation

We may process personal data where this is necessary for us to comply with a legal or regulatory obligation.

Vital interests or public interest

In limited circumstances, we may process personal data where necessary to protect someone's vital interests or where processing is otherwise permitted or required by law.

6. Health and special category data

As part of providing nutritional therapy and functional health services, we may process information relating to your physical and mental health, medical history, medication, supplements, symptoms, dietary history, lifestyle and laboratory or biochemical test results.

This information is considered special category personal data under the UK GDPR.

We only process health information where we have an appropriate legal basis and special category condition under applicable data protection legislation.

Health information is used primarily for the purpose of providing and managing your nutritional therapy and related services.

We take additional care when handling health information and maintain appropriate confidentiality and security measures.

7. Information obtained from other sources

We may receive personal data and health information from third parties where this is necessary to provide our services.

This may include:

Biochemical or functional testing companies
Other healthcare providers
Referral sources
Service providers involved in delivering services on your behalf

Where information is received from another healthcare provider, we will obtain appropriate consent where required before using that information to coordinate your care.

8. Marketing communications

We may use your personal data to send marketing communications about Freya Clinic, including newsletters, services, products, offers, promotions, events, educational content and other information that may be relevant to you.

Where consent is required, we will only send marketing communications where you have provided the appropriate consent.

Email marketing may be managed through Klaviyo, our third-party email and marketing platform.

We may use information about your interactions with our marketing communications to help us understand engagement and improve the relevance and effectiveness of our communications.

Marketing communications are optional and you can withdraw your consent at any time.

9. SMS and mobile marketing

Where you have expressly opted in to receive SMS marketing communications from Freya Lifestyle Limited, we may use your mobile telephone number to send marketing text messages relating to our services, products, offers, promotions, events, educational content and other relevant updates.

SMS marketing is provided through Klaviyo, a third-party marketing platform that we use to manage and deliver our email and SMS communications.

Where you provide consent to receive SMS marketing, your mobile telephone number, marketing preferences, SMS consent status and relevant information necessary to manage and deliver those communications may be processed by Klaviyo on our behalf.

SMS marketing consent is optional and is not required in order to purchase products or services from Freya Lifestyle Limited. SMS consent is collected separately from other forms of marketing consent where applicable.

Sharing SMS information

We do not sell your personal information.

We may share personal data, including your mobile telephone number and SMS consent status, with third-party service providers that help us provide and manage our messaging services, including Klaviyo and relevant technology or communications providers.

These providers process information on our behalf and are required to handle personal data in accordance with applicable data protection requirements.

Location information

Our SMS marketing does not use precise location information from your mobile device and we do not use location tracking or location-based services to send SMS marketing communications.

Opting out of SMS marketing

You can withdraw your consent to SMS marketing at any time by following the unsubscribe instructions provided in the SMS or replying STOP where applicable.

You may also contact Freya Lifestyle Limited directly to request removal from our SMS marketing communications.

Withdrawing consent to SMS marketing will not affect your ability to receive essential service-related or transactional communications where these are necessary to provide a service, fulfil an order or otherwise communicate with you in relation to an existing relationship.

10. Who we share your personal data with

We may share personal data with trusted third parties where this is necessary to provide our services, operate our business, process transactions or communicate with you.

These may include:

Email and marketing software providers, including Klaviyo
SMS and messaging service providers
Biochemical and functional testing companies
Payment processors and payment service providers
Website hosting and technology providers
IT and cloud storage providers
Third-party fulfilment or delivery providers
Professional advisers where necessary
Other healthcare providers where appropriate and where legally permitted
Insurance providers where necessary for legitimate verification purposes
Our professional or regulatory bodies where required
Administrators involved in payment, refund or business administration

Where we use third-party service providers to process personal data on our behalf, we take reasonable steps to ensure that appropriate contractual and security measures are in place.

We do not sell your personal data.

We do not share your health information for marketing purposes.

11. International transfers of personal data

Some of the third-party service providers we use may process personal data outside the United Kingdom.

Where personal data is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful and that your personal data receives an appropriate level of protection.

This may include using an adequacy decision, appropriate contractual safeguards such as the UK International Data Transfer Agreement or UK Addendum, or another lawful transfer mechanism recognised under UK data protection law.

12. Data retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to meet legal, regulatory, professional, accounting or reporting requirements.

Client health and consultation records will generally be retained for the period required by our professional and regulatory obligations.

Marketing information will be retained for as long as you remain subscribed to our marketing communications or where we have another lawful reason to retain it.

Where you withdraw marketing consent, we may retain limited information about your previous consent or opt-out status where necessary to ensure that we do not contact you again for marketing purposes.

When personal data is no longer required, we will take reasonable steps to securely delete or anonymise it.

13. Data security

We take reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, misuse, alteration, disclosure or destruction.

Personal data is stored using secure, cloud-based systems where appropriate.

We restrict access to personal data to those who need it for legitimate business or professional purposes.

Payment information is processed in accordance with applicable payment security requirements, including the PCI Security Standards.

Further information about PCI security standards is available from the PCI Security Standards Council.

Although we take appropriate precautions, no online transmission or storage system can be guaranteed to be completely secure.

14. Cookies and similar technologies

Our website may use cookies and similar technologies to enable the website to function, remember preferences, support shopping-cart functionality, improve the user experience and understand how visitors interact with our website.

Cookies may be used to:

Maintain website functionality
Keep track of items placed in a shopping cart
Pre-fill certain information where appropriate
Personalise elements of your website experience
Understand website usage and performance
Support marketing communications where applicable

We may also use technology that collects information such as IP address, device information and website activity for analytics and security purposes.

Where cookies or similar technologies require consent under applicable law, we will obtain that consent before using them.

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of the website.

15. Device and website information

When you use our website, we may automatically collect technical information such as:

IP address
Device type and identifiers
Browser information
Screen size
Operating system
Referring domain
Pages visited
Date and time of visits
General geographic location, such as country
Preferred language

This information may be used for website security, administration, analytics, troubleshooting and improving our website and services.

16. Digital log data

Our website and technical systems may automatically record information generated through your use of our website.

This may include:

Referring domain
Pages visited
Date and time of access
General geographic information
Preferred language
Technical information about your device and browser

This information may be used to maintain website security, understand website performance and improve our digital services.

17. Third-party websites and services

Our website may contain links to third-party websites or services.

This Privacy Policy applies only to personal data collected and processed by Freya Lifestyle Limited.

We are not responsible for the privacy practices, content or security of third-party websites. If you follow a link to another website, you should review that organisation's privacy policy before providing personal information.

18. Your data protection rights

Under applicable UK data protection law, you may have rights including:

The right to be informed about how your personal data is used
The right of access to the personal data we hold about you
The right to rectification of inaccurate or incomplete personal data
The right to erasure of your personal data in certain circumstances
The right to restrict processing of your personal data in certain circumstances
The right to data portability in certain circumstances
The right to object to certain types of processing
Rights relating to automated decision-making and profiling, where applicable
The right to withdraw consent where processing is based on consent

These rights are subject to certain legal conditions and exemptions, meaning they may not apply in every circumstance.

For further information about your data protection rights, please refer to the Information Commissioner's Office.

You also have the right to complain to the Information Commissioner's Office if you believe that your personal data has not been handled appropriately.

19. Accessing, updating or correcting your personal data

If you wish to access, update, amend or correct the personal data we hold about you, please contact:

Angela Ferguson
Freya Lifestyle Limited
Email: angela@freyaclinic.co.uk
Telephone: 07902126500

We may ask you to provide appropriate information to verify your identity before fulfilling a request.

We will respond to valid requests within the timeframe required by applicable data protection legislation.

We will not normally charge a fee for responding to a data protection rights request. However, where a request is manifestly unfounded, excessive or repetitive, we may be permitted by law to charge a reasonable fee or refuse to act on the request.

20. Marketing opt-out

You can opt out of email marketing at any time by clicking the unsubscribe link included in our marketing emails.

If you have opted in to receive SMS marketing, you can unsubscribe by following the instructions included in the message or replying STOP where applicable.

You may also contact us directly at angela@freyaclinic.co.uk to request that you are removed from our marketing communications.

Opting out of marketing communications does not affect your ability to receive essential service-related or transactional communications where these are necessary to provide a service, fulfil an order or manage an existing relationship with you.

21. Complaints

If you have concerns about how we have handled your personal data, please contact us in the first instance:

Freya Lifestyle Limited
Email: angela@freyaclinic.co.uk
Telephone: 07902126500

You also have the right to complain directly to the Information Commissioner's Office.

Information about making a complaint is available from the Information Commissioner's Office.

22. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, services, technology, legal requirements or the way in which we process personal data.

When we make changes, we will update the “Last updated” date at the beginning of this Privacy Policy.

Where appropriate, we may also notify you of significant changes through our website, email or other appropriate communication channels.

23. Contact us

If you have any questions about this Privacy Policy or how Freya Lifestyle Limited processes your personal data, please contact: