Privacy Policy
We are committed to ensuring that your personal data and privacy is protected. We understand
how important and valuable your personal data is and will only use it fairly and in ways that you
would reasonably expect us to.
This Privacy Policy explains
●Who we are
●What personal data we collect about you, and how we collect it
●Why we collect this personal data and what we do with it
●Who we share your personal data with
●How we retain your information and keep it secure
●Your rights and how to contact us
Who we are
Naomi O Connor Nutrition
Health Care Professional Council ( HCPC ) Registration Number DT29578
Codinma Registration Number MAD00992
NIE Y6973158D
Website Address: www.naomioconnornutrition.com
Our contact details
Name: Naomi O’Connor
Address: Avenida de los Penascales, Torrelodones, Madrid, Spain
Phone Number: 0034 711003302
E-mail: naomi@naomioconnornutrition.com
If you have any queries about how we use your personal data, you can contact us by emailing Naomi
O’Connor at naomi@naomioconnornutrition.com
What Personal Data we collect and how we collect it
We may collect and process the following information:
●Contact details – Name, email address, Mobile number
●Payment details – billing and payment details
●Transaction history – details of products and services you purchase
●General information about your lifestyle choices
●Specific information about your health goals and desired outcomes including your progress against these goals.
●Technical data – IP address, general location, device type, browser type and version,
operating system and platform, date and time of visit
●Usage data – information about how you use our website
We will only collect the minimum amount of personal data we need in relation to the purpose that
we need it for.
Special Category (Sensitive) Personal Data
The following personal data is classed as Special category data under the GDPR and UK Data
Protection Act 2018
●details about your ethnic or racial origin,
●religious or philosophical beliefs,
●genetic or biometric data,
●sexual orientation and sex life
●Medical and health data (including mental health)
In order to provide you with our 1:1 services, we may need to request the following special category
personal data: Information about your health including medical history, medications and medical
treatment you are receiving, recent or new diagnosis, sex life. We need this information to ensure
that it safe and appropriate to provide our nutrition and/or fertility services and health and wellbeing
coaching advice and programmes to you. We will only use this information in relation to this service.
In some cases the information you provide may be shared with another healthcare professional with
your consent or not in case of safeguarding.
We do not specifically request any other type of special category personal data from you such as
ethnic origin or religious beliefs in order to provide our services, but from time to time you may
choose to share information that is considered to be special category personal data during our initial
consultations. If it is appropriate to do so, we may make notes of the information you have shared in
respect of how relevant it is to our services agreement and the goals that we are working towards.
We will only keep a note or record of the minimum amount of special category personal data
relevant to the services we provide.
Under GDPR there are special rules for processing Special Category personal data, we must have a
lawful basis for doing so and must meet a specific condition of Article 9 of the GDPR – which is
explicit consent.
When you provide us with special category personal data, it is with your explicit consent and our
lawful basis for processing this personal data is to fulfil our contract with you.
How we get your personal data
●When you contact us to request details and more information about the services we provide
●When you sign up to our mailing list to receive regular marketing communications about our
products and services
●When you sign up to attend a workshop/masterclass/event we are hosting
●When you enter a competition or complete a survey or a quiz
●When you purchase our products / services
●When you complete a pre-service health questionnaire or a food diary
We may also collect technical data about you
●From automated technologies such as cookies, pixels, web beacons and log files when you visit
our website. This may include your IP address, your device type, operating system, browser
type, time zone or general location and referring website.
●From third parties such as social media platforms when you interact with us on social media.
●Analytics service providers (such as Google Analytics) and search engine providers.
For more information about how we use Cookies please see our Cookie Banner
If any of your personal details change after you have provided them to us, please do let us know so
that we can ensure our records are accurate and kept up to date.
We also receive personal information indirectly, from the following sources in the following
scenarios:
We may receive your name and contact details from a 3rd party Organisation such as The
International Women’s Health Centre Madrid aswell as other specialist fertility and healthcare
service suppliers, if they refer you to our services. We will use these details to contact you to find
out more about your interest in our services and to arrange your initial appointment or to to arrange
a free discovery call.
Why we collect your personal data and what we do with it
Under the UK Data Protection Act 2018 and the General Data Protection Regulations, we need to
have a purpose and a lawful basis for processing your personal data. We will only use your personal
data for the purposes that we have collected it and in accordance with data protection law. This will
be to:
●Provide a contact or service to you and manage our customer relationship
●When you have provided your consent – such as to receive marketing information from us
●When we have a legal obligation to do so – such as to comply with regulatory and statutory
reporting
●When we have a legitimate business reason for doing so, such as to manage and grow our
business, if you would reasonably expect us to do so and it does not impact on your rights,
freedoms and interests.
When you visit our website
We use automated technology such as “cookies”, pixels, beacons and log files to collect information
about how our website is used. Information gathered through cookies and server logs may include
the date and time of visits, the pages viewed, time spent at our site, and the websites visited just
before and just after our own, as well as your IP address.
We do this to understand our visitors’ behaviour, preferences and activities and to analyse and
improve and update our content and services and to maintain the secure operation and running of
our website.
For users that register on our website or on practice software and app we use called, practicebetter,
we and they store the personal information you provide in your user profile. You can see, edit, or
delete your personal information at any time. Website administrators can also see and edit that
information. When you log in, we will also set up several cookies to save your login information and
your screen display choices.
Our lawful basis is our legitimate interests to
●manage our website and business,
●maintain our systems security and prevent fraud
●to manage our marketing and business activities and improve our services.
The data that we collect about you will depend on your cookie preferences and settings. For more
information about how we use cookies please see our Cookie Banner on our website
When you sign up to receive our newsletter or download our freebie we will
●Add your contact details to our email list /database
●Save your marketing preferences
●Send you our marketing information
●Record and keep a record of your consent to marketing
Our lawful basis will be your consent.
Your consent can be withdrawn at any time, you can opt out of receiving our marketing information
by either using the unsubscribe option on our emails or by contacting us at
naomi@naomioconnornutrition.com and asking to be removed from our mailing list. When you opt
out of receiving emails and marketing information from us, we will keep a minimum of data about
you on our ‘do not contact’ list to ensure that we do not contact you further.
Like many businesses we monitor open rates and interactions with our email marketing campaigns
via automated technology within our email campaign software. Emails may contain a clear GIF
simple web beacon. Web beacons are a small clear picture file that track whether a user has
accessed the content.
We do this to understand how our subscribers interact with our email marketing campaigns and to help us improve what we send.
The information that our email software collects is your IP address, country, the device and browser
type that you used to open an email. You can set your email client to display emails as text only, or
disable cookies in your browser before opening emails to remove and prevent your information
being monitored in this way.
When you request further information about our products or services, we will
●Keep a record of and reply to your request for more information about our products or
services
Our lawful basis for doing this is because we have a legitimate business interest in responding to your
queries and requests for information to manage and grow our business.
When you sign up to work with us and request our products or services, we will use your personal
data to
●Register you as a client,
●manage our client relationship, respond to queries and communicate with you
●Send you a health/lifestyle questionnaire, food diary, cycle tracker to complete
●provide the products or service you have requested
●Set up an account on our practicebetter software and invite your to create a profile on the
practicebetter software
●Send you an invoice/take payment for the services you have requested
●We will maintain records and notes of our sessions which may include general information about
your lifestyle choices as well as specific information about your health and nutrition.
Our lawful basis will be to perform a contract with you.
We keep client records and transaction history in order to comply with statutory and regulatory
reporting requirements such as maintaining appropriate company records and business accounts and
to meet our legal requirements. Our lawful basis for doing so is our legal obligation.
Legitimate Interests: We use legitimate interests to manage and conduct our business, this may
include marketing activities and hosting events either online or in person in order to grow our
business. We may perform due diligence checks about your business before entering into a contract
with you to provide our services.
If you have attended one of our events or received any other services from us and given us feedback
or a testimonial about the services we provided, we may publish this feedback on our website, in
marketing literature and on our social media channels in order to provide testimonials and help grow
our business. We will not publish any identifying personal data in connection with any feedback
you have provided without your consent.
Marketing
Under Privacy and Electronic Communications Regulations if you are a consumer, sole trader
partnership your consent is required to receive marketing in electronic communications (including
emails, direct messages and text messages) unless you have previously done business with us or enquired about similar products or services.
If you have previously purchased or enquired about similar services from us and have not opted out
of marketing communications, we will rely on Legitimate interests to continue to send you marketing
communications. You can opt out of receiving marketing communications at any time by clicking on
the unsubscribe section of the email, or by emailing us at naomi@naomioconnornutrition.com
When sending marketing information to Limited companies and Corporations, our lawful basis for
processing your personal data for the purpose of contacting you is legitimate interests to grow and
develop our business. You can opt out of receiving marketing communications from us at any time
by clicking on the unsubscribe section of the email, or by emailing us at
naomi@naomioconnornutrition.com
When we use Legitimate Interests as our lawful basis for processing personal data, we will perform a
Legitimate Interests balancing test and we will only use your personal data in a way that you would
reasonably expect, ensuring that your rights and interests are protected.
Who we share your personal data with
We do not share or pass on your personal data to third parties for marketing purposes.
If there is an occasion where we need to refer you to a 3rd party, such as a doctor or other medica or
healthl procider we will share your personal details for them to contact you. This will be clearly
explained and agreed prior to us passing on your details.
We may share some details of your personal data with our trusted service providers and professional
advisors, such as insurers, accountants and legal advisors. We do this only to the extent necessary
for the purposes of processing our company accounts, meeting our legal obligations as a limited
company and in the event of pursuing any insurance or legal claims. When doing so we expect these
service providers and professional advisors to treat your personal data securely and only for the
purposes intended. We will only share the minimum amount of personal data necessary in these
instances.
Our service providers (such as email and cloud service hosting providers, website hosting and
payment processors) may have access to your personal data when it is stored on their systems.
These service providers only have access to your personal data for the purpose of fulfilling their
contract with us and will not use your personal data for their own purposes. When appropriate we
have relevant data processing agreements in place with these service providers.
We may share some details of your personal data with our service providers such as virtual assistants
and freelancers. When doing so we expect these service providers to treat your personal data
securely and only for the purposes intended. These service providers only have access to your
personal data for the purpose of fulfilling their contract with us and will not use your personal data
for their own purposes.
In the unlikely event of non-payment of an invoice or legal dispute, we may share your personal data
with 3rd parties in order to resolve and settle our dispute.
If and when required to do so by law, we may share elements of your personal data with appropriate
Government Departments such as HMRC or Hacienda (Spain) only to the extent necessary for the
purposes of meeting our legal obligations as a limited company/business owner.
We may share or transfer your information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of our business to another
company.
How we store your personal information
Your information is securely stored on a secured computer network and cloud based software
programs. We only use mainstream software and service providers that meet GDPR requirements
and have the appropriate measures and security protocols in place to comply with UK and EEA data
protection laws. All devices and equipment used to access and store your personal data have
appropriate data security settings in place.
We have procedures in place to deal with data security breaches in accordance with the UK Data
Protection Act 2018 and GDPR.
Sharing information outside the UK and EU
We may use cloud based platforms and service providers to store and process your personal
information that are based outside of the UK. When doing so, we comply with the UK GDPR, making
sure appropriate safeguards are in place.
We will only transfer data to countries that the UK data protection authorities have deemed to
provide an adequate level of protection. This include countries with Adequacy Regulations, or using
contracts or codes of conduct incorporating standard data protection clauses recognised or issued in
accordance with UK data protection law.
How long we keep your data
We only keep personal data for as long as necessary in relation to the purpose it was collected for.
When it is no longer required, we will dispose of your information by securely destroying the records
we hold. In some instances we may anonymise data so that personal references are no longer kept.
We keep basic client records in accordance with UK statutory law and regulatory reporting timescales
which is up to seven years. These include customer details, contact information, transaction and
payment history.
We keep detailed notes of our client sessions and food diaries for 8 years after our client sessions
have ended. After this time, wherever possible we anonymise our records to remove any of your
identifying personal data, but retain a summarised history of our client sessions to assist with
ongoing accreditation to professional bodies.
We maintain a client log including basic contact details and contact hours for 8 years
We keep names and email addresses for prospective clients on our mailing list indefinitely or until
the person asks to be removed from the mailing list.
What rights you have over your data
Under data protection law, you have the following rights:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is
inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain
circumstances. If you have been a customer and purchased our products or services, we will not be
able to delete all of your records as we have an obligation to retain some records for tax and
accounting purposes.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your
personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your
personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information
you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one
month to respond to you.
Please contact us at naomi@naomioconnornutrition.com ] if you wish to make a request.
How to complain
If you have any concerns or queries about our use of your personal information, you can contact us
at naomi@naomioconnornutrition.com .
You can also complain to the ICO if you are unhappy with how we have used your data, but please do
give us a chance to answer and resolve any queries with you beforehand.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
In Spain you can also complain to
Agencia Espanola de Proteccion de datos AEPD
Calle de Jorge Juan 6,
Madrid
28001
Telephone Number 900 293 183
Additional information
Embedded content from other websites
Articles on this website may include embedded content (e.g. videos, images, articles, etc.).
Embedded content from other websites behaves in the exact same way as if the visitor has visited
the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and
monitor your interaction with that embedded content, including tracking your interaction with the
embedded content if you have an account and are logged in to that website.
Links to Other websites
We may have links on our site to other websites that we do not operate. If you click on a third party
link, you will be taken directly to that site which is governed by its own privacy policy. We do not
control that site and assume no responsibility for the content, policies or its practices.
Cookies
To find out more about our use of cookies, please see our Cookie Policy. If you would like to delete
cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your
web browser.
You can find out more about cookies here https://www.cookiesandyou.com/
This Privacy Policy was last updated on 27th of November 2024