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Privacy Policy 

AG Nutrition Ltd ("we", "us", or "our"), operated by Adam Greer, is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal data when you visit our website https://www.adamgreernutrition.com/ or engage with our services.

Updated on November 26th, 2024.

 

This privacy policy applies to anyone visiting my website from the United Kingdom, Ireland or the European Union.

1. Data Controller

AG Nutrition Ltd

2. Who we are

Adam Greer and AG Nutrition Ltd provide nutritional therapy services to support individuals to adopt healthier diet and lifestyle habits. Our services include personalised nutritional consultations, and professional development services for nutrition practitioners, such as mentoring, clinical supervision, and training. Consultations are delivered online and in-person via The Hale Clinic. 

3. Information We Collect

We obtain personal data in the following ways:

  • Contact Us: Via email, telephone, or our website contact form.

  • Create an Account: When you register on our website.

  • Subscribe to Our Newsletter: When you opt-in to receive updates.

  • Purchase Products or Services: Including consultations, mentoring, and training.

  • Participate in Services: Such as nutritional therapy, mentoring, clinical supervision, or training.

  • Use Our Website: Through cookies and similar technologies.​​​​​​

3.1 Contact Details

  • Data Collected: Name, email address, telephone number, next of kin.

  • How We Collect Data: 

    • When you fill out forms on our website, such as the contact form

    • When you complete a nutritional therapy questionnaire

    • When you sign a terms of engagement form

    • When you call, email, or send messages via WhatsApp, Telegram, SMS or social media messaging services such as Instagram and Facebook Messenger. 

    • When making payment for services you purchase

  • Purpose: To communicate with you, respond to inquiries, provide support, and send information you request.

  • Use Limitation: We use your contact details only for the purpose you provided them for, such as responding to your inquiry or providing requested information.

  • Legal Basis: Consent (when you provide your contact details), Legitimate Interests (to respond to your inquiries).

3.2 Account Details

Data Collected: Username, password, preferences.

Purpose: To create and manage your account, provide access to restricted content or services.

Use Limitation: Account details are used solely to manage your account and preferences.

Legal Basis: Performance of a Contract.

3.3 Payment Details

  • Data Collected: Billing address, payment information (processed securely via Stripe).

  • Purpose: To process payments for purchases you make through our website or partner services.

  • Use Limitation: Payment details are used only to complete transactions and fulfill orders.

  • Legal Basis: Performance of a Contract.

3.4 Health Information

  • Data Collected: Health information you provide when engaging with nutritional therapy services, including about your medical history, dietary habits, lifestyle information, supplement and medication details, biochemical test results, clinic notes, health improvement plans.

  • How We Collect Data: 

    • When you complete a nutritional therapy pre-consultation questionnaire​

    • During consultation or telephone calls

    • When laboratories send test results that you have agreed to purchase

    • Communication via health professionals you have consented to share information with me about on your behalf

    • With your explicit consent, we may obtain information from your GP or other healthcare professionals to coordinate care.

    • Email correspondence via the Hale Clinic, when you have contacted them to request a referral and shared information voluntarily on your contact form. 

    • Email correspondence via my professional organisation, BANT, if you provide this information in a practitioner search query form intended for me to read. 

  • Purpose: To provide tailored support services based on your health needs.

  • Use Limitation: Health information is used only with your explicit consent and solely for providing the services you requested.

  • Legal Basis: Explicit Consent.

3.5 Newsletter Subscription

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  • Data Collected: Email address.

  • Purpose: To send newsletters and updates if you have explicitly consented.

  • Use Limitation: Used only to send newsletters; you can unsubscribe at any time.

  • Legal Basis: Consent.

3.6 Website Analytics

  • Data Collected: IP address, browser type, pages visited, general location.

  • Purpose: To improve our website and understand how users interact with it.

  • Use Limitation: We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website. This data is anonymised and cannot be used by us to identify you directly.

  • Legal Basis: Legitimate Interests.

3.7 Cookies

Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor. Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

  • Purpose: To enhance your experience, personalise content, and analyse website usage.

  • Use Limitation: Cookies are used only with your consent; we provide a detailed cookie policy if you'd like to read more. You can also manage your preferences when you access the site.

  • Legal Basis: Consent.

3.8 Compliance with Legal and Regulatory Requirements

Data Collected: Financial transaction records, client health records.

Purpose:

  • We retain financial transaction records, including details of services or products purchased, for 7 years in accordance with UK tax regulations. 

  • For client health records, we retain this information in compliance with UK GDPR and relevant professional guidelines:

    • For 8 years after the conclusion of services

    • If you purchase nutrition services for your child, we are required to keep information you provide until your child reaches their 25th birthday.

    • If a client is 17 years old when we begin working together we are required to keep their information until your child reaches their 26th birthday, or 8 years after the conclusion of services, whichever provides the longer retention period, to comply with legal and regulatory standards. 

Use Limitation: Data is retained only as required by law and not used for any other purpose.

Legal Basis: Legal Obligation.

4. Third-party Sharing​

When necessary, sometimes we share your data with third party service providers, with your explicit consent. This includes: 

4.1 direct sharing

  • We will seek your express consent before sharing your information with your GP or other healthcare providers. However if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests

  • Practice management services like Swandoola or Practice Better. 

  • Laboratories to process tests like Medichecks, Viva Health Laboratories, Genova Diagnostics, Invivo Healthcare, Regenerus Labs, Team Gene, Functional Diagnostix Ltd, or Lifecode Gx. 

  • Companies that can provide discounted supplements (e.g. The Natural Dispensary, Invivo Healthcare)

  • If you purchase in-person consultations at the Hale Clinic, we may share contact details, or other relevant details such as if you have specific accessibility requirements:

    • When scheduling appointments

    • If you purchase their phlebotomy services

    • When referring to another service within the clinic

  • Our registrant body, CNHC, and our professional association, BANT, for the processing of a complaint made by you​

  • Any relevant and necessary contractors and advisors that provide a service to us or act as our agents, where this is unavoidable, on the understanding that they keep the information confidential

  • Anyone to whom we may transfer our rights and duties under any agreement we have with you. For instance, if you request your data is transferred to another practitioner, or if we am required to do so due to ill-health or in the event of Adam's death, retirement or termination of business.

  • Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g., CNHC, ICO) if we have a duty to do so or if the law allows us to do so

  • With your explicit consent, we may share your case history in an anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites. We will seek your explicit consent before processing your data in this way and explain the types of details shared, how they will be used, and your right to to refuse, or to change your mind, is always respected.

  • With your explicit agreement, we may share your testimonial for promotional services, on this website, or third party channels such as social media. If you agree, you will be asked to specify where and how your testimonial can be used, and the degree of anonymity you prefer. You will never be coerced or required to provide a testimonial for any reason and can change your mind at any time. 

4.2 Indirect Sharing

  • If you purchase services via my website, or another platform, you will need to provide your payment details to my payment provider, Stripe. 

  • If you prefer to arrange a direct debit or direct bank transfer that you set up manually, your banking provider will share your details with my banking provider, Starling bank, to complete and record the transactions.

  • If we consult via Zoom video conferencing, the email address and IP address, or telephone number you use to join the meeting will be identifiable. Zoom also have their own privacy policy. You can also read their GDPR compliance statement and cookie policy.  

  • If you engage with our website, Google Analytics will receive anonymised data, alongside our website hosting provider Wix. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

  • If you click on any links on our website pages that direct you to other websites for additional relevant information or services, always remember that these sites have their own privacy policies, which we can't control. Before providing personal information to any third-party site, please read their privacy policy carefully. While we choose links with care, all websites carry some risk. Consider adjusting your browser settings for added security or using reputable internet security services to reduce your risk when clicking on external links. We strive to keep this website secure, but using any website carries inherent risks. Always be cautious when clicking on links or interacting with online services.  

All third party service providers we use comply with GDPR and are bound by data protection agreements which are publicly available on their websites. 

5. Securing Your Data

We only use information that may identify you in accordance with UK GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

 

Within the health sector, we also have to follow the common law duty of confidentiality, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

  • Security Measures: To protect your personal data from unauthorised access, use, or disclosure, we implement a range of security measures, including data encryption, firewalls, password protection managers, regular change of passwords, access controls, and regular security reviews. We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
     

  • Protecting Your Payment Data: I take payment security very seriously. When you purchase services on my website or through Swandoola.com or Practicebetter.com (my clinic management systems), your credit card information is protected by 256-bit SSL encryption. The payment gateway, currently Stripe, follows strict security protocols which adhere to the standards set by the Payment Card Industry Data Security Standard (PCI-DSS) as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by my website and its service providers.
     

  • Data Storage: Our company website (https://www.adamgreernutrition.com/) is hosted on the Wix.com platform, which allows us to share information and provide products or services to you, including publicly accessible website pages such as this one. Wix.com store your data in secure databases and general applications held on servers protected by firewalls. Wix.com also provide our website its payment gateways which adhere to industry standards. We provide more details about this if you're interested. 
     

  • Practice Management: If you purchase a nutritional therapy service, we use third-party practice management systems, such as Swandoola and Practice Better for managing appointments and services, as well as to store and secure your health data in one place.​

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements.

6.1 Health Records

  •  Adults: Retained for 8 years after the conclusion of services.

  •  Children under 18: Retained until their 25th birthday.

  •  Clients aged 17 at service start: Retained until their 26th birthday or 8 years after services conclude, whichever is longer.

6.2 Financial Records

  • Kept for 7 years, as required by UK tax regulations.

6.3 Contact Details

  • Newsletter Subscribers: Until you unsubscribe.

6.4 Website Usage & Cookies

If you have visited this website and consented to receive cookies, data confirming your consent can be stored for up to one year, unless you subsequently withdraw your consent. Other cookies may vary. You can find more details in my cookie policy page. To make this website load faster, it uses 'caching', which stores a temporary copy of web pages. Sometimes, third parties need to access this temporary cache for technical support. They only access it when necessary and cannot use the data further.

7.0 Your Legal Rights Under GDPR

  • Right to Access: You can request a copy of the personal data we hold about you.
     

  • Right to Rectification: You can ask us to correct any inaccuracies in your personal data.
     

  • Right to Erasure: You can request that we delete your personal data under certain conditions.
     

  • Right to Restrict Processing: You can ask us to limit how we use your data.
     

  • Right to Data Portability: You can request that we transfer your data to another organisation or directly to you.
     

  • Right to Object: You can object to the processing of your data if we are relying on legitimate interests.
     

  • Right to Withdraw Consent: If we are processing your data based on consent, you can withdraw it at any time.

To Exercise Your Rights:

 

Please contact us in writing:

We are legally required to respond within 30 days of receiving your request, and all necessary information from you. Our professional organisation, BANT, recommends that we aim to respond within 20 days under most circumstances. In most instances, we will respond sooner, however we do not have any administrative support, so depending on the nature of your request, or if I'm unable to access your data due to travel, vacation, ill-health or other personal/technology-related reasons, some requests may take longer to process. 

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Our response will include:

  • The details of the personal data we hold on you including:

  • Sources from which we acquired the information

  • The purposes of processing the information

  • Persons or entities with whom we are sharing the information under GDPR.

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Note: Exercising certain rights may affect our ability to provide services to you. For example, if you request deletion of essential health data, we may not be able to continue providing nutritional therapy services. Under special circumstances, some information may be withheld, where it is required for legal and regulatory compliance.

8.0 Essential Data

Certain personal data is essential for us to provide our services effectively:

8.1 Nutritional Therapy Services

  • Required Data: Health information, contact details, and payment information.

  • Reason: Without this data, we cannot create personalized health plans or comply with legal and professional obligations.

  • Legal Basis: Performance of a Contract, Legal Obligation.

8.2 Clinical Supervision Services

  • Required Data: Your name, contact details, qualification, professional membership status, and insurance provider, your client's consent to discuss their case with a supervisor, anonymised data about your client's health and lifestyle habits, and your payment information.

  • Reason: Without this data, we cannot discuss your clients case, nor provide other clinical supervision services, to comply with legal and professional obligations.

  • Legal Basis: Performance of a Contract, Legal Obligation.

8.3 Mentoring Services

  • Required Data: Your name, contact details, and if you are already in practice, your qualification, professional membership status, and insurance provider, your business name and website details, your ICO registration, and your payment information.

  • Reason: Without this data, it will be difficult to ensure you are eligible for the services we provide, and to provide practical support. Some information is essential to comply with legal and professional obligations.

  • Legal Basis: Performance of a Contract, Legal Obligation.

8.4 Courses and Groups

If you purchase a learning-on-demand (pre-recorded) professional development course that requires restricted access to certain sections of my website, such as to the learning portal and private discussion groups, some specific details are essential:

  • Required Data: Name, email address, payment details.

  • Reason:To grant access to course materials and member-only content.To protect intellectual property and ensure only authorised access.To track engagement for CPD requirements.To provide technical support, and to safeguard discussion group mem

  • Legal Basis: Performance of a Contract, Legitimate Interests.

9.0 Children's privacy

This website is for adults. We don't knowingly collect information from children on this website, and we do not sell or market any products or services directly to children. If you are the legal parent or guardian or a child, and you'd like Adam to provide nutritional therapy services to your child, we can only accept payments, emails, contact requests and set-up accounts via the referring adult parent or guardian. Please see section 6.1 of this privacy policy to learn more about how long your children's data is retained when you refer for support. 

10.0 Changes to this policy

We may update this Privacy Policy from time to time.

Notification of Changes: Significant changes will be communicated via email or a notice on our website. Information about when the policy was last updated is available at the top of this page.

11.0 Automation and AI

We do not carry out any automated processing, which may lead to automated decision based on your personal data, such as machine learning or artificial intelligence (AI) based decision-making. 

12.0 Complaints 

If you're not happy with how we handle your data, please contact us by email: contact@adamgreernutrition.com or telephone: +447946151357. If we cannot resolve your concerns within 30 days, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). You can contact them on 01625 545745 or 0303 1231113.

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