Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested before contacting us or ordering any Goods from us using Our Site.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
• “Account” means an account required to access and/or use certain areas and features of Our Site;
• “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
• “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About Us
Our Site is operated by Routes to Nutrition Limited, a Company registered in England and Wales under Company number 14452164. Our registered address is Unit 82A James Carter Road, Mildenhall, Bury St Edmunds, IP28 7DE UK. Our Information Commissioners Office registration number is: ZB417811.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our or my collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our my use of your personal data or exercising your rights as outlined above, please contact us me using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out below:
• identity information which you supply including name, title, date of birth;
• contact information which you supply such as your name, postal address, email address or telephone number;
• history of orders you have placed;
• anonymous web analytics data about the pages which you visit on this website, the referring sites or search terms, and the country in which you are located;
• your IP address, browser type and version, and operating system.
When we provide you with nutritional therapy services, we may collect:
• information which you provide to us in the health questionnaire or other documentation you send us including information about your medical history;
• information about the results of any medical tests or investigations which you send to us;
• the results of any medical tests or investigations which we arrange for you.
Please also see Part 14 for more information about our use of Cookies and similar technologies.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
We will use the data we collect to:
• supply goods and services which you have ordered;
• manage payments for our goods and services;
• communicate with you in response to messages you send us via the website;
• supply you with information by email that you have opted-in-to
• detect and prevent fraud or malicious use of the website
When we provide you with nutritional therapy services, we will use the data we collect to:
• prepare nutritional advice;
• contact you to discuss your nutritional therapy services or to send you reminders to arrange follow-up consultations or tests;
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
We will retain your data while we are providing you with goods or services and for a period of up to three years thereafter. You can ask us to erase your data at any time.
9. How and Where Do You Store or Transfer My Personal Data?
We use the following service providers for storage of data, processing of orders and payments and administration of Our business. Please refer to the privacy policies of each provider for further details.
• Google (document storage)
• monday.com (client administration)
• Intuit QuickBooks (accounting)
• Royal Mail (delivery)
• Stripe (payment gateway)
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
10. Do You Share My Personal Data?
The results of tests which we arrange for you are processed by the following third parties. Please refer to the privacy policies of each party:
• Hair Tissue Mineral Analysis – Mineral Check
• Organic Acid Test – Regenerus Labs
• GI Map Test – Nordic Laboratories
• Genetic Test – MaxGen Labs
• Food Intolerance Testing – Cambridge Nutritional Sciences
We may ask you for your consent to share your test results anonymously with other nutritional practitioners in order to obtain their guidance regarding your nutritional therapy services.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
12. Can I Withhold Information?
You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for usage tracking and analytics, and detection and prevention of fraud or malicious use.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so.
The following first-party Cookies may be placed on your computer or device:
• eCommerce shopping session tracking and cart contents
• account session tracking
and the following third-party Cookies may be placed on your computer or device:
• Google web analytics
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: contact@routestonutrition.co.uk
Postal Address: 82A James Carter Road Mildenhall IP28 7DE.
16. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
17. Attribution
This Privacy Policy has been created using a document template from www.simply-docs.co.uk.
Last updated: 26 October 2022