Last updated 14th September 2019
If anything is unclear or you have questions, please don’t hesitate to contact the Data Protection Officer on firstname.lastname@example.org
Whether you’re a one-to-one or online subscription member, or you’re visiting our website for the first time, we want you to know that your personal information is important to us and we value the trust and faith you put into The Nutrition Plan to deliver the best service and support to help you succeed with your weight loss.
We explain the ways in which your personal data is used if you’re:
- a one-to-one member
- an online subscription member
- a visitor to our websiteWHAT INFORMATION WILL THE NUTRITION PLAN COLLECT ABOUT ME?
When you join as either a one-to-one or online subscription member, we need some personal information to manage your membership and to ensure our nutrition services are effective and suitable for you. This information can include:
- contact details such as your name, email address, postal address, telephone or mobile number
- information such as your gender or date of birth
- information about your medical history and health to help us provide guidance and support through the programme
- throughout your membership we will collect information relating to your nutrition, exercise, your weight and your weight loss progress. We may also record other personal details provided by you, which we will use to help provide you with the most effective support
You can only become a member if it’s appropriate and safe to do so, and we fully understand that this information is personal and needs to be kept secure and private.
If you participate in, access or sign up to any of The Nutrition Plan's services, activities or online content, such as email newsletters, competitions, live chats, message boards, web and mobile notifications, telephone, or create an account using our online registration system, we may receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, gender and date of birth, as well as information collected about your use of The Nutrition Pan (such as what you read or watch on The Nutrition Plan website).
Where we provide personalised services we may ask your permission to review third-party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation. Some of our services enable you to sign in via a third-party service, such as Facebook or Facebook Messenger. If you choose to sign in via a third-party app, you will be presented with a dialog box which will ask your permission to allow The Nutrition Plan to access your personal information (eg your full name, date of birth, email address and any other information you have made publicly accessible). Please note that any information that is not required by the particular service you have opted to use will not be retained by The Nutrition Plan.
PASSIVE INFORMATION COLLECTION
We may use third party software to passively collect information while you are visiting our Website (that is, you do not actively provide this information). These technologies allow us to collect certain kinds of non-personally identifiable information, including your internet domain name, the type of web browser you use, the device and operating system you use, the date and time of your visit to our website, the specific pages you visit, and the address of the web site you visited prior to entering our website. We do not link this passively collected non-personally identifiable information with personally identifiable information you have actively provided elsewhere on this site. This data is used only to help us improve our customers’ experience on ourwebsite and we reserve the right to share the anonymous aggregated information that we have passively collected via our website with third parties, including our business partners and advertisers.
The Nutrition Plan uses Google Analytics and Hotjar to compile usage statistics. These services are provided by Google, Inc. and Hotjar Limited, respectively. Their terms can be found here http://www.google.com/privacy
, and https://www.hotjar.com/legal/policies/privacy
Below we have summarised the primary means of passive information collection on our Website.
INTERNET PROTOCOL (IP) ADDRESSES
This site uses Internet protocol (IP) addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. IP addresses allow us to collect much of the same information we collect through cookies, including browser type, what pages you visit, and how long you stay on the site. In general, IP addresses allow us to identify problems with our servers, prepare aggregate demographic information and other information regarding this use of this site, and improve the functions of this site.
Sometimes we will ask you for additional personal information, and sometimes sensitive personal information (eg if you’ve entered a competition or sent in your story to be used for publicity). When we do this we only use the personal information with your explicit consent, and we will provide further information at the time about why we’re collecting your information and how we’ll use it.
WHAT IF MY SUCCESS STORY OR CONTENT IS SELECTED FOR PUBLICITY?
, any user content you post in our online community or send to us on Messenger or via email, is automatically licensed to us through a worldwide, royalty-free perpetual licence. This licence grants us a transferable right to use, record, reproduce, distribute, publish and create derivative works based on your user content (in whole or in part) as The Nutrition Plan. We may use this content in any format, media or technology. We will only use this content in an appropriate way which respects you as a member of our online community.
We promise that we will not publish information that:Reveals your physical or online address or any other information that allows members, website or social media users to directly contact you, unless you give us permission to publish your social media handle.Gives medical or other personal information that is not directly relevant to your weight loss story.Identifies children or any other young person without their parents’ or legal guardians’ consent.Identifies any other person without that person’s consent – e.g. your spouse or partner, your friends or other relatives.
We will store your information in relation to your story as follows:Your personal information and photographs (provided by you and/or commissioned by us) in relation to your nutrition plan story will be held on our secure servers located in the EEA.
If you have any concerns about the use of your data, contact the Data Protection Officer
HOW WILL THE NUTRITION PLAN USE THE INFORMATION IT COLLECTS ABOUT ME?
The Nutrition Plan will use your personal information for a number of purposes including the following:
- To provide our online content, services and activities, or to provide you with information about them and to deal with your requests and enquiries.
- To contact you in relation to our nutrition services. We will not send you unrelated marketing material, nor will we transfer your personal information to third parties for marketing purposes.
- To ensure we’re publishing content users need and want, The Nutrition Plan website collects information about your usage of our site. We only use this information in aggregated form (so that no individuals are identified) for improving the website. For more information, read our Passive information collection section above.
- To provide you with the most user-friendly online navigation experience.
- We may analyse the information you supply, as well as your activity, so we can offer a more tailored service. For example, we could use your website viewing history to provide personalised menu recommendations.
- When using our website, or if you’ve subscribed to our email newsletters, we may use your information to inform you of special offers and provide other marketing information which we think you may find of interest. If you’d rather not receive this information, you can opt out by emailing the online support team or by simply clicking the link to unsubscribe at the bottom of any marketing emails.
Where The Nutrition Plan proposes using your personal information for any other uses, we will ensure that we notify you first and, if necessary, seek your consent.
YOUR ONLINE ACCOUNT
If you’ve registered for an account, all your information is stored in a single database for use by all of our web services.
Where you provide personal data, including health information, through the website, Messenger, on the telephone or by any other means, we may use this information to provide you with tailored features and functionality.
We may use carefully selected third parties to help improve the quality of our offering, and to help us shape the creation of new services by storing, tracking and analysing user preferences and trends and to ensure that your use of our online products and services is right for you. At all times The Nutrition Plan is the owner of the information collected through our online products and services.
We work with GoCardless for our online payments. Details such as credit/debit card numbers are not stored by us.
As someone who has registered for one of our products, we may invite you to take part in research studies. Your participation is entirely voluntary and you’ll always be asked for your consent before taking part.WHEN WILL THE NUTRITION PLAN CONTACT ME?
The Nutrition Plan may contact you about any service, activity or online content you’ve signed up for, to ensure we can deliver our services, e.g. to verify your email when you sign up for an online account, or to help you reset your password.
We may also contact you for the following reasons:
- about correspondence we receive from you or any comment or complaint you make about The Nutrition Plan products or services
- about any personalised services you’re using
- about any contribution you’ve submitted to The Nutrition Plan, e.g. on any message boards, via social media or Messenger to invite you to take part in surveys about The Nutrition Plan (participation is always voluntary)to update you on any material changes to our policies and practices
- for marketing purposes, as set out in the section ‘Will I be contacted for marketing purposes?
We will never contact you to ask for your The Nutrition Plan account password, or other login information.
WILL I BE CONTACTED FOR MARKETING PURPOSES?
The Nutrition Plan will only send you marketing emails or contact you where you’ve agreed to this. We do not sell or share your personal information for marketing or promotion of any third-party products.
When you sign up as a one-to-one or online subscription member we will only send you emails about the services we provide.
When you become a member of The Nutrition Plan your email address is added to our database and we may use your email to contact you directly about our services, products or information that we believe might interest you. If your membership lapses we may send you reminder emails of our services while your details remain on our database as a member (see the section ‘How long will The Nutrition Plan keep my information?’).
When you sign up for our marketing emails via our website, we add your email address to our database and may use your email address to contact you directly about services, products or information we believe might interest you. We may use a third-party marketing service to send marketing emails on behalf of The Nutrition Plan, and you can easily opt out of receiving further marketing emails from The Nutrition Plan by simply clicking the link to unsubscribe at the bottom of any marketing emails.
Transactional emails (e.g. receipts, and notifications about your membership) will continue to be delivered to you during your active membership with The Nutrition Plan, regardless of whether you’ve opted into receiving marketing and support emails.
WILL THE NUTRITION PLAN SHARE MY PERSONAL INFORMATION WITH ANYONE ELSE?
The success of The Nutrition Plan depends upon your trust and we do not sell or share your personal information for marketing or promotion of third-party products.
Sometimes The Nutrition Plan uses third parties to process your information on our behalf, for example to provide our online services or for analysis. The Nutrition Plan requires these third parties to comply strictly with its instructions and we demand that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way.
OFFENSIVE OR INAPPROPRIATE CONTENT ON THE NUTRITION PLAN WEBSITE AND SOCIAL MEDIA PAGES
If you post or send content which may reasonably be deemed offensive, inappropriate or objectionable anywhere on The Nutrition Plan website or social media pages, or otherwise engage in any disruptive behaviour on any The Nutrition Plan service, we may remove such content.
Where The Nutrition Plan reasonably believes that you are, or may be, in breach of any applicable laws, for example on hate speech, The Nutrition Plan may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. The Nutrition Plan would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection law.
HOW LONG WILL THE NUTRITION PLAN KEEP MY INFORMATION?
We will only hold your personal information on our systems for as long as is necessary for the relevant service you’ve signed up for.
As a one-to-one or online subscription member the personal information you give us will be kept for a maximum period of 36 months after your last subscription service was delivered. During this period your details are retained as a lapsed member in case you want to reactivate your membership. We know from our experience that many members want to reactivate their membership and retain their previous nutrition journey. We may contact you about the service you’ve signed up for during this period.
In addition, some personal information is held for longer:
- as part of our research to help us develop our methods and services. In this case, access is carefully restricted. The information is used only for statistical purposes and is held only as long as is necessary to complete the research
Where we obtain your consent to use your personal information for publicity or promotional purposes, including:
- on social media
- on our websites
We will retain that information until such time as you withdraw your consent, or the information is no longer suitable for the intended purpose. We will review the personal information held for publicity or promotional on at least an annual basis to identify what is no longer suitable for this purpose so it can be deleted.HOW SECURE IS MY PERSONAL INFORMATION
We follow strict security procedures in the processing and disclosure of information which you have given us, to prevent unauthorised access and as required by data protection legislation.
At The Nutrition Plan, we understand the value of security and have implemented security policies, rules and robust physical, electronic and managerial procedures to safeguard and secure the personal information we have under our control from unauthorised access, improper use and disclosure, unauthorised destruction or accidental loss.
The personal information and data held on laptops and other equipment used is protected from unauthorised access. All data electronically transferred is encrypted and sent by secure methods.
Wherever we use a carefully selected third party to help provide our services, we will always ensure your personal information is processed to the same strict security procedures as indicated in this policy.
Personal information and data is held on secure servers.DO YOU TRANSFER MY DATA TO ANY OTHER COUNTRIES?
All personal information in relation to our digital platforms is stored on secure servers within the UK or EEA.
Where the personal information of a data subject from the European Economic Area is controlled and processed by The Nutrition Plan, appropriate safeguards are in place to ensure the rights and privileges of the data subject are protected.CAN I DELETE MY DATA?
You can decide how you use our services and what information you provide to us.
If you stop subscribing to our services, that is you cease to be an active member, we still retain your personal information in accordance with our retention policy outlined above.
However, we will consider requests to delete data, unless we have a legal right or obligation to retain your Information. For example, we may retain information about your customer identity, such as name and payment history, to help us manage any financial queries that you might raise with us in the future. Furthermore, we may retain personal information for research, or an anonymised version of your personal information. Any use of this personal information would only continue as permitted under this policy.
If you ask us to delete your personal information while you’re an active member, this may result in you no longer being able to continue as a member of The Nutrition Plan.
If you’d like us to cancel your membership, delete your personal information or if you don’t want us to share any information we hold about you with third parties, please contact us on email@example.com.
CAN I FIND OUT WHAT PERSONAL INFORMATION THE NUTRITION PLAN HOLDS ON ME?
Under the data protection legislation you have the right to request a copy of the personal information The Nutrition Plan holds about you and to have any inaccuracies corrected.
Please contact us if:
- you’re worried that any information we may hold about you is incorrect
- you want to see what personal information we hold about you (and receive a copy)
- you have any queries regarding the accuracy or the processing of your data (including any misuse or unauthorised use)
- you want to withdraw your consent where any processing is based upon consent
We may require you to confirm your identity with two forms of approved identification such as:
- driving licence
- utility bill (from the last three months)
- current vehicle registration document
- bank statement (from the last three months)
You have the right to see whatever information we hold about you. Please send your request to the Data Protection Officer (contact details below) and we will respond to your request promptly and always within 30 days.
We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information we hold about you.
Please address any requests and questions about this Privacy Promise to firstname.lastname@example.org
We will include the date of any changes or updates on this page.
If you do not agree to any of the changes or updates, please don’t continue to use The Nutrition Plan websites or to submit personal information to The Nutrition Plan. You should contact the Data Protection Officer
to discuss your concerns.
If you’re worried that any information we may hold about you is incorrect, then please let The Nutrition Plan know and we will update our records.
Please contact The Nutrition Plan’s Data Protection Officer if you:
- want to withdraw your consent for any purpose for which it has been provided
- are concerned about the misuse or unauthorised use of your personal information
If you’re within the UK, please address any requests and questions about this Privacy Promise to: email@example.com
If you’re unhappy or dissatisfied with our response to any concerns you have raised about the security or use of information we hold in relation to you, you can complain to the appropriate supervisory authority. In the UK this is the Information Commissioner