Privacy Policy

This is the privacy notice of MyHalsa which is operated by Hälsa Wellbeing Ltd. In this document, “we,” “our”, or “us” refer to (trading or business or organisation or company name) Hälsa Wellbeing Ltd.

This privacy notice applies to information we collect about:

• Visitors to our website https://www.halsawellbeing.com/ and https://myhalsa.life/
• People who email us.
• Complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry.
• People who use our services.
• Data Sharing agreements with organisations we are contracted to work with.
• Job applicants, former and current employees.
• Contractor therapists who work on behalf of Hälsa Wellbeing.
• People who make a query or a complaint.

Introduction

1. This is a notice to inform you of our policy about all information we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means to collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
8. The bases on which we process information about you
9. The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
10. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
11. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Website Use

1.          Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2.          Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at [email protected] or www.halsawellbeing.com. However, if you do so, you may not be able to use our website or our services further.

3.          Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

4.          Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

• tagging an image
• clicking on the icon next to another visitor’s message to convey your agreement, disagreement or thanks
• leaving comments on blog posts

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do store it, and we reserve the right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at info@halsawellbeing or www.halsawellbeing.com

5.          Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

6.          Information relating to your method of payment

This site is subject to the terms and privacy policies of WooCommerce and PayPal. This site is built using WordPress and uses WooCommerce function to take and process orders. This site’s payment processing system is run using PayPal.  WooCommerce and PayPal may have access to your information as they support this site in its authorised use of your information. Their terms and conditions and privacy policies are available on their websites.

7.          Sending a message to our support team

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Use of information we collect through automated systems when you visit our website

8.          Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website
• to record whether you have seen specific messages we display on our website
• to keep you signed in our site
• to record your answers to surveys and questionnaires on our site while you complete them
• to record the conversation thread during a live chat with our support team

9.          Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed in to our website.

10.      Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve you an advert for our products or services when you visit some other website.

We may use a third party to provide us with remarketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information

11.      Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

No such information is personally identifiable to you.

12.      Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

13.      Credit reference

To assist in combating fraud, we may share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

14.      Data may be processed outside the European Union

Our website is hosted in the United Kingdom

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

Access to your own information

15.      Access to your personal information

• At any time, you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
• To obtain a copy of any information that is not provided on our website you may send us a request at [email protected].
• After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

16.      Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at [email protected].

This may limit the service we can provide to you.

17.      Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

18.      Use of site by children

• We do not sell products or provide services for purchase by children, nor do we market to children.
• If you are under 18, you may use our website only with consent from a parent or guardian

19.      Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

20. People who Email Us

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

21. People Who Make a Complaint to Us

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide.

We usually must disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

Usually we do not identify any complainants unless the details have already been made public.

22. People Who Use Hälsa Wellbeing’s Services

We must hold the details of the people who have requested the service to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes.

For insurance purposes we must keep treatment records for a minimum of seven years.  This information will be kept in a secure environment and only accessed on a needs only basis.

23. Job Applicants, Current and Former Employees of Hälsa Wellbeing Including Contractors

Hälsa Wellbeing is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information, please contact Charlotte Underwood at [email protected]

What Will We Do With the Information You Provide Us?

All the information you provide during the process will only be used for the purpose of processing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

What Information Do We Ask for and Why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for, but it might affect your application if you don’t.

Application Stage

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

Assessments

We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test, or we might take interview notes. This information is held by Hälsa Wellbeing.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be held for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise. 

Conditional Offer

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability. 

You will therefore be required to provide: 

• Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
• Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
• You will be asked to complete a criminal records declaration to declare any unspent convictions
• We will contact your referees, using the details you provide in your application, directly to obtain references

If we make a final offer, we will also ask you for the following:

• Bank details – to process salary payments
• Emergency contact details – so we know who to contact in case you have an emergency at work

Use of Data Processors

Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. 

How Long is Information Held For

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

How We Make Decisions About Recruitment

Final recruitment decisions are made by hiring managers and members of our recruitment team. All the information gathered during the application process is considered.

You can ask about decisions made about your application by speaking to Charlotte Underwood – Head of Operations on Head Office Telephone:  03300 552122 or mobile: 07889 503925.

24. Your Rights

Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

25. Access to Personal Information

Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you, we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.

To make a request to Hälsa Wellbeing for any personal information we may hold you need to put the request in writing addressing it to:

Emma Avhede,

Managing Director Hälsa Wellbeing

29 Hornbeam Square South
Harrogate
HG2 8NB

Or email [email protected]

26.      How you can complain

• If you are not happy with our privacy policy or if you have any complaints then you should tell us by email. Our address is [email protected].
• If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
• If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

27.      Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

28.      Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we would like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

29.      Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any questions regarding our privacy policy, please contact us.