Privacy Policy
Introduction
Welcome to FND Wellbeing Limited. Please read this Privacy Policy (“Policy”) carefully before using the www.fndwellbeing.com website (“Website”) and any of its products or services (“Services”) operated by FND Wellbeing Limited (“us”, “we”, “our” or “FND Wellbeing”).
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​Your privacy is important to us and we respect your privacy regarding any information we may collect from you across our Services. This Policy sets out and governs how FND Wellbeing collects, stores, uses and shares information about you when using or interacting with our Website. This Policy applies to all visitors, users and others who wish to access or use these Services.
Children's Privacy
Our Services are intended for users who are at least of an age of 18 years. If you are under the age of 18 years, you cannot use or register to use these Services so please do not provide your personal information.
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We do not knowingly collect personal information from minors. If you are a parent or guardian and you learn that your children have provided us with Personal Information, please contact us as soon as possible. If we become aware that we have collected personal information from a minor, the personal information will be deleted as soon as possible.
How we collect information
FND Wellbeing collects information when you use and interact with the Services, e.g. through contacting us, signing up for subscriptions and updates, placing an order or booking coaching sessions either through our Website or correspondence (including via social media platforms), completing registration forms, or signing up for content such as webinars and newsletters. This includes your use and interaction with our Website, using cookies for the purposes of analytics and to improve our Services and features. Information can be collected through correspondence and enquiries too.
What information we collect
We collect your name, contact details, information you have chosen to share to access the Services about you, social media information (e.g. including platforms, handle names, information shared with FND Wellbeing), payment information e.g. your credit or debit card details for contractual purchases, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable), engagement history and transaction history.)
Log data
When you visit our Website and use the Services, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details. This is being used for analytics and to provide the Service’s features.
Cookies
Most web browsers automatically accept cookies but you can modify your settings to decline them if you prefer by instructing your browser to refuse all cookies or to indicate when a cookie is being sent. If you choose to do this, you may find that you cannot make full use of the Service. Please refer to our “Cookie Policy” for more information.
Correspondence
Email, Website Chat and messaging: When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number, information you choose to share and the information contained in any signature block in your email). This is with the intention of being able to interact and respond to any requests or questions around the Services provided.
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Social Media: FND Wellbeing uses Facebook, Messenger and Instagram to provide Services, interact and correspond with users engaging with content. We collect the platform you use, your handle name and profile information that you share on social media together with any information you provide through chat and messaging services provided. This is with the intention of being able to interact and respond to any requests or questions around the Services provided.
Courses & Workshops
When you decide to sign up for courses and workshops we collect your information that is pertinent to providing you with our Services and any other information that you choose to share with us to enable you to access the Services in the best way possible (such as your name, email address, telephone number, banking details where purchases are made to facilitate our contractual obligations, and types of learning support required). This allows us to interact and correspond about the courses or workshops you have registered an interest in and enable the provision of any Services you have signed up for.
There will also be a register of the courses and workshops you have attended inline with retention guidelines outlined later in this document. This is to enable us to identify Services that you would specifically be interested in to build on previous Service provision, e.g. to go deeper on a particular area of interest, rather than send out bulk marketing emails.
1-2-1 Consultations
Discovery Call: When you contact us through the email address displayed on our Website, through Chat or Social Media platforms to request a Discovery Call, we collect your details as outlined in “Correspondence” above.
In addition, you will be sent an Enquiry Form to outline the reason for your enquiry and to establish some basic health and wellbeing context in preparation for the call. This information is being used in order to make contact with you to discuss your requirements and see if the Services provided by FND Wellbeing match your requirements and/or to enable signposting to other methods of support where applicable.
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Wellbeing 1:1 Coaching sessions: When you decide to sign up for wellbeing coaching sessions we collect your information that is pertinent to providing you with this specific service to fulfil our contractual obligations. It can also include any other information that you choose to share with us to enable you to access the Service in the best way possible (such as your name, email address, telephone number, banking details to book sessions online through the Website and types of learning support required). This allows us to tailor the sessions to your specific needs and create a safe environment for you to work within.
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You will be given a copy of this Policy so that you are aware in advance how the information provided will be used in the course of our sessions together. You will be asked to provide information through the completion of a Confidential Client Form (includes information around the impact of Functional Neurological Disorder (FND) symptoms to understand how best to support you) and a Client Contract with terms and conditions of engagement.
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All personal and sensitive information, particularly regarding symptoms of FND and its impact, are subject to the UK, Article 9 (g) - Subsection 16. of the Data Protection Act 2018 (Support for individuals with a particular disability or medical condition). This information is sensitive and is tightly monitored, controlled and destroyed safely for confidentiality and to comply with all UK legal obligations. The data provided for these sessions is kept in complete confidence with FND Wellbeing unless the client asks us to share it with a third party and provides written permission to do so. It is important to ensure that you are safely supported throughout the sessions and your needs are adapted to in the best way possible.
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Session content: Notes are kept with the intention of providing a visual prompt to track expectations, intentions, progress, reflections of the journey and a record of the work undertaken to provide an effective service. A summary of key points from the session will be provided to users of this service for their own informational purposes and so they have a copy for their own purposes. These notes must comply with the regulations outlined in the paragraph above.
How we use your information
Your information is used for administrative and business purposes (particularly to contact you and process orders you place, to improve our business and website, to fulfil contractual obligations, to advertise our Services and those of others, to analyse your use of our Website, and in connection with our legal rights and obligations.)
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information is where we have:
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Your consent. You are able to remove your consent at any time. Details of how to do this are in the section below, “Your Rights”;
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A contractual obligation;
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A legal obligation; or
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A legitimate interest.
Retaining your information
Your personal information shall be retained for as long as we are legally required or permitted to do so to fulfil any legal obligations and any other legal basis we have for using your information.
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Correspondence: When you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, then archive this information for a period of 6 months to allow for follow up enquiries.
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Order information for Courses, Workshops and Coaching Sessions: When you place an order for Services, we retain that information for seven years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax and auditing purposes.
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Subscription to Updates and Newsletters: We retain the information you used to sign up for our newsletter for as long as you remain subscribed.
Removal of data
All personal data will be deleted from electronic devices and servers, and hard copies of information will be shredded and destroyed, safely and securely at the end of any retention period through regular information audits to comply with the Law and this Policy.
Storage and security of information
Your information is securely stored on cloud based servers hosted by Wix.com and Google. Their associated Privacy Policies/Notices are here:
https://policies.google.com/privacy?hl=en-US#infosecurity
https://www.wix.com/about/privacy
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While we retain your information, we take action to protect it within commercially acceptable security safeguards, to prevent loss and theft, as well as unauthorised access, collection, use, disclosure, copying, modification, disposal, destruction, or similar risks. No method of transmission over the internet, or method of electronic storage is 100% secure. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the absolute security of user data beyond what is reasonably practical.
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If we learn that you are affected by a data breach we will notify you within 72 hours of discovering the breach.
Disclosure of your information to third parties
Your information can be shared with partners for specific types of content and events where you have registered a specific interest in their information and/or Services. Other disclosures are only to the extent necessary to run our business, to our service providers, to fulfil any contracts and provide Services we enter into with you as well as where required by law or to enforce our legal rights.
Selling your information to third parties
FND Wellbeing does not sell information to third parties. However, when you register or sign up for certain types of content, your registration data can be shared with sponsors and partners to enable the third party Service to be provided to you as outlined in the “Disclosure of your information to third parties” above.
The limits of our Policy
Our Service may, from time to time, contain links to other websites of interest that are not operated by us. However, once you use these links please be aware that you have left our Services and we do not have any control over other websites and their information. We cannot be held responsible for the protection and privacy of any information which you provide when visiting such sites and these sites are not governed by this Policy. Please exercise caution and look at the privacy statement applicable to the website(s) you are visiting.
Your rights and controlling your personal information
You have various rights with respect to the collection and use of your information through our Website, Social Media and Services. They are as follows:
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Choice and consent: You do not have to consent to the collection of information. However, if you choose not to provide it, we may not be able to work with you to provide our Services.By providing personal information to us, you explicitly consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy.
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Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Right to be informed: This Policy provides you with Privacy information.
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Right of access: You may request details and/or a copy of the personal information that we hold about you. If you wish to see your file then please make a request in writing. We will provide you with the information within 30 days of your request. You may be required to prove your identity before given access to your personal information.
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Right to rectification: This is your right to request changes to any information we hold that is factually inaccurate. If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us to make the relevant changes.
Right to erasure: You may request that we erase the personal information we hold about you at any time. Given the requirements of our legal obligations, we are required to hold your details for a period of 7 years, after which your information will be securely destroyed.
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Right to restrict processing: You may require that we will restrict processing your data in certain circumstances, e.g. until any complaint is resolved.
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Right to data portability: You may request that we transfer your personal information to another third party, or to you, in certain circumstances. If you ask us to transfer the information we hold to a third party then we will do so. We will not share your information without your specific consent, other than in the situations described above.
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Right to object to data processing activities: You have the right to object to us using your personal data for any particular purpose and in certain circumstances.
Our contact details and how to register a request or complaint
If you have any concerns about this Policy or your data, and/or you wish to make a request or complaint, please contact the data controller. The data controller in respect of our website is: FND Wellbeing Limited.
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You can contact the data controller through the Website Chat function or by sending an email to fndwellbeing@gmail.com.
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You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Changes to this Policy
This Policy may be amended from time to time in order to maintain compliance with the Law and to reflect any changes to our data collection and handling processes. We recommend that you periodically review this Policy to ensure that you are familiar with any updates.
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If we make a material change to this Privacy Policy, for example changing a lawful basis on which we process your personal information, we will notify you through the contact details you have provided us, or by placing a prominent notice on our website.
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Your continued use of the Service after any changes to this Policy will be regarded as your acknowledgment of the modifications and your consent to abide and be bound by our modified practices around privacy and personal information. If you do not agree to be bound by the terms and conditions of the new Policy, you are no longer authorised to use the Service.
23 August 2023