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Privacy Policy

Introduction

This Privacy Policy outlines Kyklos Nutrition ("we", "our" , "us" or "the Company") practices with respect to information collected from users who access our website ("Site") or otherwise share personal information with us (collectively: "Users").

 

Kyklos Nutrition holds some information about you. This policy outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to info@kyklosnutrition.com.

 

What We Do

Kyklos Nutrition provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, we aim to understand the underlying causes of your health issues which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.  

 

User Rights

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data. 

 

If you want to access your data you must make a subject access request in writing to info@kyklosnutrition.com. Under special circumstances, some information may be withheld. We shall respond within 10 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:

 

  • Sources from which we acquired the information

  • The purposes of processing the information

  • Persons or entities with whom we are sharing the information

 

You have the right, subject to exemptions, to ask to: 

  • Have your information deleted

  • Have your information corrected or updated where it is no longer accurate

  • Ask us to stop processing information about you where we are not required to do so by law or in accordance with the BANT and CNHC guidelines. 

  • Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, without hindrance from us. 

  • Object at any time to the processing of personal data concerning you

 

We do not carry out any automated processing, which may lead to automated decision based on your personal data. 

 

If you would like to invoke any of the above rights then please email info@kyklosnutrition.com

 

Retention

All records held by Kyklos Nutrition will be kept for the duration specified by guidance from our professional association BANT and registrant body CNHC.

 

Grounds for data collection 

Processing of your personal information (i.e. any information which may potentially allow your identification through reasonable means; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

 

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

 

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

 

What information do we collect?

We collect two types of data and information from Users. 

 

The first type of information is unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

 

The second type of information Personal Information, which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

 

  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

 

  • Registration information: When you register with our Site you will be asked to provide us certain details such as: full name; email or physical address, and other information.

 

How do we receive information about you?

We receive your Personal Information from various sources:

  • When you voluntarily provide us with your personal details on our Site; Our electronic forms on our site make use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate. 

  • When you use or access our Site in connection with your use of our services;

  • From third-party providers, services and public registers (for example, traffic analytics vendors).

 

Information provided by you:

You provide us with personal data in the following ways:

 

  • By completing a nutritional therapy questionnaire

  • By signing a terms of engagement form

  • During a nutritional therapy consultation

  • Through email, over the telephone, Whatsapp messaging or by post

  • By taking credit card and online payment  

 

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 our holding your personal data is for legitimate interest.  

 

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

 

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.

 

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. 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 which 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. We may use your data for statistical and analytical purposes, intended to improve the Site.

 

Do you share my information with other organisations?

We will keep information about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

  • Our registrant body, CNHC, and our professional association, BANT, for the processing of a complaint made by you

  • Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential

  • Anyone to whom we may transfer our rights and duties under any agreement we have with you

  • Any legal or crime prevention agencies and/or to satisfy any regulatory request (eg, CNHC) if we have a duty to do so or if the law allows us to do so

We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. We will not include any sensitive information.  

 

We will seek your express consent before sharing your information with your GP or other healthcare providers. However, if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

 

We may share your case history in an anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites. We will seek your explicit consent before processing your data in this way.

 

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

 

In addition to the purposes listed in this Privacy Policy, we may share Personal (Non-Medical) Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

  • Hosting and operating our Site;

  • Providing you with our services, including providing a personalised display of our Site;

  • Storing and processing such information on our behalf; 

  • Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;

  • Providing you with marketing offers and promotional materials related to our Site and services; 

  • Performing research, technical diagnostics or analytics;

 

We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

 

Cookie Policy

Refer to our Cookie Policy.

 

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

 

How do we safeguard your information?

We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful. 

 

Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. 

 

We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed. 

 

Kyklos Nutrition is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).

 

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

 

You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

 

Marketing

We may use your Personal Information such as your name, email address, telephone number, etc., for the purpose of providing you with promotional materials concerning our services which we believe may interest you.  

 

To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists. 

 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

 

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

 

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us: info@kyklosnutrition.com

 

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

 

Complaints

If you have a complaint regarding the use of your personal data then please contact us by email info@kyklosnutrition.com and we will do our best to help you.

 

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 0303 1231113.

 

How To Contact Us

If you have any general questions about the Site or the information we collect about you and how we use it, you can email info@kyklosnutrition.com

 

Last Modified

We keep our Privacy Policy under regular review. This Privacy Policy was last reviewed in April 2023. 

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