Privacy Policy

Policy version: 01.04.2024

1. Introduction

This Privacy Policy is provided by ADAPT WELLNESS LTD (“We”). We are registered in England and Wales under company number 15006599 and have our registered office at Bayside Business Centre, Unit 1 Sovereign Business Park, Willis Way, Poole, England, BH15 3TB (‘we’, ‘our’ or ‘us’) for use of our services including our website and wellbeing (Services).

We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy sets out how we collect, handle, store, and protect information about you when providing our Services.

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2. What this policy applies to

This Privacy Policy applies to your use of our Services only, including interactions on our website, and digital and in-person wellness services.

3. Personal data we collect about you

We collect data necessary to provide you with our Services, including:
Identity and Contact Data: Name, email, address, phone number, and emergency contact details.
Account Data: This includes information that you provide to us when you create or log into your account, such as your username, password, and other security details for authentication and access. It also includes details about your account usage and activity, such as your transaction history, interactions with our services, and the timing, frequency, and duration of your activities.
Health and Wellness Data: Information about your physical health, medical history, and wellness goals necessary for tailoring our services to your needs.
Service Usage Data: Information on how you use our services, your preferences, feedback, and survey responses.
We may also collect data about you via cookies. For more information, please visit our Cookies Policy.

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4. Sensitive Data

We handle sensitive data, particularly health-related information, with extra care and confidentiality. We do not collect data about your health, racial or ethnic origin, political opinion, religious beliefs, trade union membership, genetic data, biometric data, or sexual orientation unless it is volunteered by you and necessary for the provision of our Services.

5. Location data

For services that require geographical location (e.g., home visits), we will request your consent to use location data. If you do not provide consent, certain in-person service features may be limited.

6. How we collect personal data

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services, your account with us or via our website or indirectly, such as your activity while using the Services.

Please read our Cookies Policy for information about data we collect via cookies or similar technologies on our website.

7. How and why we use your personal data

We use your personal data:
To provide and improve our Services.
To give you access to your account with us.
For customer service and support.
For internal record keeping and managing your account.
To comply with legal and regulatory obligations.

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

8. Marketing

We may use your personal data to send you information about services we think might interest you. Where you are an existing customer or prospect, we will rely on our legitimate interests to send such marketing information provided you had the opportunity to opt-out when we collected your details. In all other cases, we will only send you marketing materials where you have expressly consented to receive such marketing information. You can opt out of receiving marketing communications at any time by contacting us or clicking the unsubscribe link in emails you receive.

9. Who we share your personal data with

We may share your data with service providers who assist us in delivering our Services. These include IT and system administration providers, customer management providers and medical and other wellness professionals when necessary.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We also ensure that our service providers are contractually bound so that they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:

external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

10. How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to eight years thereafter to comply with HCPC standards for physiotherapists and also to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once your contract with us has ended, your data is encrypted, and we will move it to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

11. Transferring your personal data out of the UK

At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

12. Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here. Your rights include the right to:

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please contact us via email , call or write to us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

13. Keeping your personal data secure

We have appropriate security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

14. How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

15. Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via our website or by other means, such as email.

16. How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:

Email: Hello@adaptwellness.co.uk
Address: Adapt Wellness Bayside Business Centre, Unit 1 Sovereign Business Park, Willis Way, Poole, England, BH15 3TB
Phone number: 07783921482