Privacy Policy

Ludo’s Primal Wellness Ltd

Privacy and Data Protection Policy June 2018

Who we are

Ludo’s Primal Wellness Ltd is a health and fitness company registered at 4 West Regent Street, Glasgow, G2 1RW.

Background

This privacy and data protection policy lets you know what happens to any personal data that you give to us, or any that we may collect from or about you in carrying out our duties to support development of your fitness, health and wellness. It applies to all products and services, and instances where we collect your personal data.

Our commitment

Ludo’s Primal Wellness Ltd is fully committed to handling personal information in accordance with data protection legislation and best data handling practices. This means that your personal information will be:

  1. Processed lawfully, fairly and in a transparent manner
  2. Collected for specified, explicit and legitimate purposes
  3. Only collected so far as required for our lawful purposes
  4. As accurate and up to date as possible
  5. Retained for a reasonable period of time, in accordance with retention policies
  6. Processed in a manner which ensures an appropriate level of security

Whether through this notice or otherwise, we hope to ensure that everyone has a good understanding of why Ludo’s Primal Wellness Ltd processes personal information and, where we do, the rights they may have.

Why do we need to process or hold personal data?

In order to provide contracted services with clients and members, we need to process personal data to undertake a health assessment, understand your current levels of fitness, deliver personal and group fitness training or other products and services which you contract from us. This information helps us to support you effectively on your journey to improving your health and wellbeing.

How do we collect personal information?

Like most organisations that handle personal information, there are various ways in which Ludo’s Primal Wellness Ltd collects information from and about the people we deal with:

  • From you directly via email and written correspondence, telephone discussions and at face to face appointments
  • Client membership and medical forms when we start working with you and other information requests
  • Visitors to our website: ludosprimalwellness.com
  • Information generated about you when you engage our health and fitness services, for example through your ongoing use of our online nutrition and movement app
  • Business partners (for example, our partner, Glasgow Medical Rooms, appointed nutritionists, physiotherapists or fitness coaches) or others who are a part of providing your services or operating our business
  • From other sources such social media, internet, news articles

What kinds of personal information about you do we collect?

Personal information that we’ll process in the delivery of our health and fitness services includes:

  1. Clients
  • Personal and contact details, such as title, full name, contact details, social media accounts where we link with you and contact details history
  • Records of your contact with ussuch as via email, telephone and face to face meetings
  • Financial information detailing associated payment methods and receipts raised because we have received payments from you for memberships or other delivery of our services
  • Your usage of our services: records of health and fitness services provided for you, relevant correspondence relating to the delivery of those services plus any testimonials you may have provided for us
  • Imagery, where you have provided this for our use in delivering health and fitness services
  1. Service providers or interested third parties
  • Personal and contact details, such as title, full name, contact details, social media accounts where we link with you and contact details history
  • Financial information: bank account and sort code to enable settlement of invoices for work delivered at our request
  • Qualifications and professional experience
  • Your delivery of services on our behalf: records of health and fitness services provided by you, relevant correspondence relating to the delivery of those services

What do we use your personal data for?

We use your personal data, including any of the personal data listed above, for the following purposes:

  • Assessing how best to support you with your health and wellness journey, identifying what are the most appropriate techniques and programmes to help deliver this, any risks, availability of payment method and the terms
  • Management of all aspects of the health and fitness services we deliver for you
  • To improve the operation of our business and that of our business partners
  • To follow guidance and best practice under the change to rules of governmental and regulatory bodies
  • For management and auditing of our business operations including accounting
  • To monitor and to keep records of our communications with you
  • To comply with legal and regulatory obligations, requirements and guidance
  • To provide insight and analysis of our clients both for ourselves and for the benefit of business partners so we can improve our service offering
  • To share information, as needed, with our service providers as part of providing and administering our services or operating our business

What is the legal basis for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

  1. Contractual purposes:

We need to collect your personal information so that we can manage the agreed schedule of work with you:

 

  • Set up and administer your account with us
  • ensure correct invoicing and appropriate payment for health and fitness services delivered
  • ensure we can access the required information in order to deliver effective health and fitness advice
  • send you communications by post or email in relation to essential elements of our work with you

 

If you do not provide us with all of the personal information that we need to collect then this may affect our ability to offer the above services.

 

  1. Legitimate interest:

 

We also process our clients personal information in pursuit of our legitimate interests to:

  • For management and audit of our business operations including accounting
  • To carry out monitoring and to keep records of our communications with you and our staff
  • For market research and analysis and developing statistics
  • To help us improve products or services, or to assess or to improve the operating of our business
  • Where we need to share your personal information with third parties in order to run our business or comply with any legal and/or regulatory obligations
  • Share case studies of individual health and wellness improvements by clients, with their permission, in order to increase awareness of the services that Ludo’s Primal Wellness Ltd provides
  • Events and activities which we undertake from time to time for clients may be photographed or filmed and your personal information maybe used in images captured from those events which we use for promotional purposes

 

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on [insert email address]

Does Ludo’s Primal Wellness Ltd share data with third parties?

Some of the processing activities set out above may require us to share personal information with third parties. Whenever we share personal data, we take all reasonable steps to ensure it will be handled appropriately and securely by the third party. The following is a list of the main third parties with whom Ludo’s Primal Wellness Ltd may share personal information:

  • Oversight regulators and statutory bodies (e.g HMRC)
  • Our bank: Barclays
  • Third party service providers who support some of our business functions, including:
    • Glasgow Medical Rooms
    • Sonnda Catto Nutritionist
    • Creditfix, who provide our digital marketing and email marketing support
    • Flourish Marketing
    • Creditfix finance department
    • Edinburgh marathon festival
    • Great Scottish run
  • Software providers which allow Ludo’s Primal Wellness Ltd to operate efficient digital processes, including:
    • Virtuagym
    • DropBox
    • Mailchimp
    • Microsoft Office 365
    • Microsoft Outlook
    • GoogleAdBox
    • Google Analytics
    • Linkedin, Twitter, Facebook, Instagram and other social media platforms
    • Hootsuite
    • PracticeWeb
    • JustHost
    • GoDaddy
    • Woocommerce
    • Evento Market
    • Wetransfer
    • WordPress
    • Tiny scanner

For practical reasons, this is an indicative, but not exhaustive list. Please also note that the list may be updated from time to time.

For how long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
  • For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
  • Retention periods in line with legal and regulatory requirements or guidance.

Where does Ludo’s Primal Wellness Ltd store your personal data?

Personal information is mainly processed by us at:

  • our registered address
  • our operating address: Regent house, Renfield street, Glasgow G2 1NQ
  • remotely when working on site, outdoors or at client locations
  • at the offices of our appointed third party service providers listed above

To allow us to operate efficient digital processes, we sometimes need to store information in servers located outside the UK, but never without first ensuring that they are compliant with GDPR.

What are your rights when we are processing or controlling your personal information?

Here is a summary list of the rights that all individuals have under data protection laws.

  • Access to your information – you have the right to request a copy of the personal information about you that Ludo’s Primal Wellness Ltd holds
  • Correcting your information – we want to make sure that your personal information is accurate, complete, and up to date, and so you may ask us to correct any personal information about you that you believe does not meet these standards.
  • Deletion of your information – You have the right to ask Ludo’s Primal Wellness Ltd to delete personal information about you where:
    • You consider that we no longer require the information for the purposes for which it was obtained
    • Ludo’s Primal Wellness Ltd is using that information with your consent and you have withdrawn your consent – see ‘withdrawing consent to using your information’ below.
    • You have validly objected to our use of your personal information – see ‘objecting to how we may use your information’ below.
    • Ludo’s Primal Wellness Ltd’s use of your personal information is contrary to law or our other legal obligations.
  • Objecting to how we may use your information – you have the right at any time to require Ludo’s Primal Wellness Ltd to stop using your personal information for direct marketing purposes.
  • Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold, or assessing the validity of any objection you have made to Ludo’s Primal Wellness Ltd’s use of your information. The right might also apply if we no longer have a basis for using your personal information but you don’t want us to delete the data. Where this right is validly exercised, Ludo’s Primal Wellness Ltd may only use the relevant personal information with your consent, for legal claims, or where there are other public interest grounds to do so.
  • Withdrawing consent using your information – where we use your personal information with your consent, you may withdraw that consent at any time, and we will stop using your personal information for the purpose(s) for which consent was given.

Please contact Ludo’s Primal Wellness Ltd by email at hello@ludosprimalwellness.com or in writing to our office at 4 West Regent Street, Glasgow G2 1RW if you wish to exercise any of these rights.

 

Changes to this policy

 

Ludo’s Primal Wellness Ltd keep this notice under regular review and clients will be contacted of any changes to this policy. Paper copies of the privacy statement may also be obtained by emailing hello@ludosprimalwellness.com or in writing to our office at 4 West Regent Street, Glasgow G2 1RW.

 

This privacy statement was last updated on 13 June 2018.

 

Complaints

 

While Ludo’s Primal Wellness Ltd seeks to resolve directly all complaints about how we handle personal information, you also have the right to lodge a complaint with the Information Commissioner’s Office, whose contact details are as follows:

 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone – 0303 123 1113 (local rate) or 01625 545 745

Website – https://ico.org.uk/concerns