PRIVACY POLICY
Introduction
Our wellbeing and coaching services are operated by Klip Global Ltd (“Klip Global”). We are a UK-based company with the registration number 12799673 and our registered office is Twelve Quays House Egerton Wharf, Birkenhead, United Kingdom, CH41 1LD.
Klip Global understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website at www.klipglobal.com (the “Website”). We will collect and use your personal data in which that are described in this Privacy Notice, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested if you use our website and/or services.
Information about us
As part of the services we offer, we are required to process personal data about our staff, our service users and, in some instances, the friends or relatives of our service users and staff. “Processing” can mean collecting, recording, organising, storing, sharing, or destroying data.
Our company is an ICO (Information Commissioner's Office) registered company ZB336419. We are committed to protecting your privacy and ensuring that your information is secure. In order to safeguard and secure the information we collect online and through our application, we have put in place suitable physical, electronic, and managerial procedures to prevent any unauthorised access or disclosure.
We have a dedicated team who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us via team@klipglobal.com or our registered address above.
We are committed to being transparent about why we need your personal data and what we do with it. This information is set out in this privacy notice. It also explains your rights when it comes to your data.
What Does This Policy Cover?
This Privacy Policy applies only to your use of our Website and services, Our Website 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.
Service Users
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.
What data do we collect?
In order to provide a safe and professional service, we may need to keep certain records about you. Depending on your use of our Website and/or services, we may collect and hold some or all of the personal data set out in the table below. We may process the following types of data:
Identity Data includes title, first name, last name, and gender
Contact Data includes home address, email address and telephone numbers
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform, and visited web pages prior to coming to our website
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses
Usage Data includes information about how you use our website, products, and services
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
To provide you with a complete service, we may also occasionally collect special category data in accordance with the requirements of the Data Protection Legislation. This data includes:
Data concerning Health includes mental and physical health, relationships & communities, meaning and habits
Racial or Ethnic Origin
Schedule 1 of the DPA 2018 provides conditions for processing special category and criminal offence data and some of these conditions require us to have an Appropriate Policy Document (‘APD’) in place, setting out and explaining our procedures for securing compliance with the principles relating to the processing of personal data in Article 5 of the GDPR and policies regarding the retention and erasure of such personal data.
We process Special Category Data under the following GDPR Articles:
Article 9 (a) Explicit consent
Article 9 (h) Health or social care (with a basis in law)
Article 9 (i) Public health (with a basis in law)
Why do we have this data?
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.
It is in our legitimate interest to ensure that our platform is presented to you in the most effective way possible, improve our website and app, and detect any fraudulent behaviour. We need this data so that we can provide high-quality care and support. By law, we need to have a lawful basis for processing your personal data.
We process your data to:
Comply with any applicable laws
Provide our wellness and fitness services to clients
Manage our relationship with clients
Gain feedback from our clients
We may also process your data with your consent. In the event that we need to ask your permission, we will provide you with a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent at any time.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes. 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 always have the opportunity to opt-out.
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.
Complying with applicable laws
We use your personal information for the following purposes:
to comply with our legal obligations.
to enforce our legal rights.
protect rights of third parties; and
Who do we share your personal information with for these purposes?
We may share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection enforcing our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Providing our Goods and Services to clients
We collect and maintain personal information that you voluntarily submit to us by email, or during your use of the Website and our services. We use the personal data you provide to us so that we can fulfil the supply of services you have engaged us to provide.
Who do we share your personal information with for this purpose?
We might share your personal information with the following categories of third parties:
Storage - third party cloud storage providers that store our data on secure servers.
What is our legal basis?
It is necessary for us to use your personal information in this way to perform our obligations in accordance with any contract that we may have with you, or to which the data subject is otherwise a party.
Managing our relationship with clients
Our Website features a Contact Us short enquiry form which invites you to submit general enquiries. We collect the personal data you submit to us when making your enquiry.
Where you are a prospective client, we may use personal information that you voluntarily submit to us to prepare proposals for your purchase of our Services, to contact you, or otherwise to manage or administer our relationship with you.
Who do we share your personal information with for this purpose?
We do not actively share your personal information with any third parties, but we do store your data using secure servers based in the cloud.
What is our legal basis?
It is in our legitimate interest to use your personal information to ensure we optimise our service provision for you.
Gaining feedback
From time to time we may contact you to invite you to provide feedback about our Website or services. Alternatively, you may submit queries or feedback to us via the Contact us short enquiry form on our Site. We use this information to help us improve the quality of service provided by us. We also use your feedback to monitor the quality of our services and to assist with the selection of future interactive features and service lines.
Who do we share your personal information with for these purposes?
We do not share this data routinely but may use a third-party service provider to assist us with customer surveys and feedback requests.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
Where do we process your data?
So that we can provide you with high quality care and support we need specific data. This is collected from or shared with:
You or your legal representative(s).
Third parties.
We do this, via phone, via email, via our website, via application forms, or via our applications.
Third parties are organisations we might lawfully share your data with. These include:
Other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, clinical commissioning groups, and other health and care professionals.
The Local Authority.
Your family or friends – with your permission.
Organisations we have a legal obligation to share information with, i.e., for safeguarding, the CQC.
The police or other law enforcement agencies if we must by law or court order.
Our website
To ensure that our Website is of highest quality and to provide you with the best experience while using our Website, we process some data about you.
As part of our Sites we use certain cookies, analytics, beacons, and other technologies of which you should be aware. These are small files or text pieces that are downloaded to a device when a visitor accesses a website or application. Please see our Website and Cookie Policy to find out more about the categories of cookies we use and how to manage and delete cookies.
Storage and Transfer
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
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.
Your rights
The data that we keep about you is your data and we ensure that we keep it confidential and that it is used appropriately. Under the Data Protection Legislation, you have the following rights when it comes to your data:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
The right to access the personal data we hold about you.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
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. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain our data in line with the Information Governance Alliance’s guidelines (https://digital.nhs.uk/data-and-information/looking-after-information/data-security-and-information-governance/codes-of-practice-for-handling-information-in-health-and-care/records-management-code-of-practice-for-health-and-social-care-2016)
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
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.
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.
You may need to provide adequate information for our staff to be able to identify you, for example, a passport or driver’s licence. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.
If you would like to complain about how we have dealt with your request, please contact:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
https://ico.org.uk/global/contact-us/
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
Changes to this Privacy Notice
We may change this Privacy Notice 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 Website and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our Website following the alterations. We recommend that you check this page regularly to keep up-to-date.
This Privacy Notice was last updated on September 14, 2022.