Privacy Policy
The Feel Good Focus is operated by T K Morgan Health Solutions Ltd; you can find out more about the company here. Throughout this Privacy Policy, ‘we’, ‘us’ and ‘our’ means T K Morgan Health Solutions Ltd.
This Privacy Policy sets out how we collect and process your personal data.
We may share your personal information with other companies that provide services on our behalf, but we can assure you that we will never sell your personal data. We are committed to safeguarding your privacy; keeping your personal data safe and secure is our top priority.
Categories of Personal Data The Feel Good Focus collects
The categories of personal data about you that we may collect, use, store, share and transfer are:
Individual Data
This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, title, date of birth, gender and your contact details such as your billing address, delivery address, email address and telephone numbers.
Advertising Data
This includes personal data which relates to your advertising preferences, such as whether you open our emails (and if you do what links you click on), information about your preferences in receiving marketing materials from us and our third parties and your communication preferences.
Information Technology Data
This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication data, browsing behaviour information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices (which include computers as well as hand held devices such as mobile phones and tablets) that you use to access our website.
Account and Profile Data
This includes personal data which relates to your account or profile on our website, such as your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Economic and Financial Data
This includes personal data which relates to your finances, such as your payment card details and information which we collect from you for the purposes of the prevention of fraud.
Sales Data
This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you and details of products and services you have purchased from us.
Health Data
This includes personal data relating to your current or former physical or mental health, including information about any healthcare you have received from us or other healthcare providers such as GPs, dentists, or hospitals (private and/or NHS), which may include test results, referral letters, prescription or treatment details, photos, information you provide when communicating with our doctors, details of clinic and hospital visits, as well as medicines administered.
Special Category Data
We may obtain some of your more sensitive data such as personal data revealing racial or ethnic origin, the processing of genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
Market Research Data
This individual data which is gathered for the purposes of market research, such as price comparison information.
Aggregated Data
This includes personal data which relates to your account or profile on our website, such as your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
The sources from which The Feel Good Focus obtains your personal data
We obtain your personal data from the following sources:
1. Directly from you, either in-person, via video calls, via our website or by telephone or via computers and handheld devices including mobile phones and tablets. This could include personal data which you provide when you:
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enter into a contract with us for the provision of healthcare and lifestyle services;
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use any healthcare and lifestyle services provided by us;
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create an account on our website;
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request information on our products or services or for other marketing to be sent to you;
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correspond with us by letter, email or telephone;
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complete a survey from us or give us feedback;
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purchase a consultation from us the payment confirmation for which shall be sent to us by Adyen (via Wix, or such other payment processor as we appoint from time to time).
2. Indirectly from other sources. We may also collect personal data about you from third parties when:
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you are referred to us for the provision of healthcare and lifestyle services;
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we deal with experts (including medical experts) and other service providers about services you have received or are receiving from us (such as a laboratory);
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we liaise with credit reference agencies;
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we liaise with debt collection agencies; and/or
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we liaise with Government agencies, including the Home Office and HMRC.
3. Analytics providers and social media platforms
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analytics providers (such as Google Analytics);
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search information providers (such as Facebook, Google Ads and Microsoft Bing Ads);
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providers of social media platforms (such as Facebook, Twitter and Instagram) for example where you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter.
How The Feel Good Focus uses your personal data
We collect personal data about you in order to:
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Perform our contractual obligations to you
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Processing data for the purposes of a contract to which you are a party to. There’s a range of legal and regulatory requirements we and our parent company need to comply with, and some of these may affect the way we process personal data, or the length of time we are required to keep it.
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registering you as a customer;
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providing you with healthcare and lifestyle related services and to communicating with you in relation to the same (including in relation to complaints);
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communicating with any other individual that you ask us to update about your care, including family members and other healthcare professionals;
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using our systems to compile and organise your answers to our health questionnaire to enable our healthcare professionals to better assess your health, and understand your healthcare and lifestyle needs;
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making or receiving payments, fees and charges;
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collecting and recovering money owed.
Consent
You’ll be asked to confirm that you’re happy to provide your personal data and that you give permission to The Feel Good Focus to process your personal data. All of the details such as why The Feel Good Focus want your data, how it will be used and if your data will be shared, will be provided at the time of asking you for your consent. Where The Feel Good Focus are relying on consent you will usually see a tick box.
For certain purposes it may be appropriate for us to obtain your prior consent such as our marketing activity. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
In the event that we rely on your consent, you may at any time withdraw the specific consent you give to our processing your personal data. Please email us at info@thefeelgoodfocus.com to do so.
Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other lawful bases to process your personal data for other purposes.
Legal Obligations
The Feel Good Focus will on occasion be under a legal obligation to obtain and disclose your personal data.Where possible The Feel Good Focus will notify you when processing your data due to a legal obligation, however this may not always be possible:
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processing is necessary for the establishment, exercise, or defence of legal claims;
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Or compliance with legislation;
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prevent and detect fraudulent or criminal activity we may share information with forces such as the Police. This is done in a safe and secure manner. You may not be notified of this.
Public Interest
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The processing is necessary for the performance of a task carried out in the or in the exercise of official authority vested in us.
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To protect individuals or society from the risk of harm or death, such as from a serious communicable disease or violent crime.
Legitimate Interests
The Feel Good Focus process personal data for our own legitimate business interest. This relates to us managing our business to enable us to give you the best service/products and most secure experience. When we rely on this, we’ll carry out a legitimate interest assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.
Our legitimate business interests don’t automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to do so by law.
Our legitimate interests include:
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the provision of our healthcare and lifestyle services and goods;
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the recovery of debt;
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the provision of administration and / or technology services;
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the security of our technology network;
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the prevention of fraud;
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marketing of goods and services and promotion of our business;
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the reorganisation or sale or refinancing of the business or a group restructure;
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the study in how to develop, update and improve our products and services;
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to invite you to participate in clinical trials;
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the development of our business strategy;
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protecting our business and property.
Extra conditions for sensitive personal data
Where we are processing your sensitive / special category personal data one of the following conditions will also apply:
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you have given your explicit consent to the processing;
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the processing relates to personal data which are manifestly made public by you;
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the processing is necessary for the establishment, exercise or defence of legal claims;
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the processing is necessary for archiving purposes in the public interest;
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the processing is necessary to protect an individual’s vital interests where the individual cannot give consent;
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the processing is necessary for reasons of substantial public interest;
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processing is necessary in relation to your or our rights in the field of employment and social security and social protection law;
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processing is necessary for the purposes of preventative or occupational medicine; and
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processing is necessary for reasons of public interest in the area of public health.
Keeping in touch
We will always ask you if you want to receive offers and information from us and via what channels you are happy to receive them.
If you have opted into to receive email and digital communications, you will receive traditional emails but may also receive marketing online and via social media platforms.
If you have opted into marketing using your lifestyle and health information, we will send you offers on healthcare products and services that you buy.
Some of our marketing selection processes are fully automated so that we can ensure we’re selecting offers, products and services that are the most relevant for each customer. We combine our data with demographic data that we obtained when you signed up, such as your gender, your age and where you live. This aggregated data is then compared against our other customers to understand you better.
Please be aware that as our marketing campaigns are prepared well in advance, you may still receive material by post for up two months, and by e-mail or text for up to 28 days after updating your preferences.
Who receives your personal data from The Feel Good Focus
We may disclose your personal data to:
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our group companies and affiliates or third-party data processors who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Policy;
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a doctor, nurse, carer or any other healthcare professional involved in your treatment, including your GP, pharmacist, dentist or other clinicians (including their medical secretaries);
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other members of support staff involved in the delivery of your care, such as admin staff, personal trainers, and other staff delivering The Feel Good Focus sessions
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Royal Mail or other delivery service providers;
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anyone that you ask us to communicate with or provide as an emergency contact (e.g. your next of kin or carer);
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private sector healthcare providers;
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third parties who assist in the administration of your healthcare, such as insurance companies;
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national and other professional research/audit programmes and registries;
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government bodies including the Home Office and HMRC as well as our regulators, like the Care Quality Commission, Regulation and Quality Improvement Authority, Health Inspectorate Wales and Healthcare Improvement Scotland;
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the police and other third parties where reasonably necessary for the prevention, investigation, prosecution, or detection of crime;
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our insurers;
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debt collection agencies;
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credit referencing agencies;
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our third-party services providers such as technology suppliers, actuaries, auditors, lawyers, document management providers and tax advisers;
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third parties who provide marketing or digital advertising services, such as marketing and PR agencies, email platforms, analytics software providers, survey tools and social media platforms;
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law enforcement agencies, courts, or other relevant party, to the extent necessary for the establishment, exercise, or defence of legal rights;
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third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution, or liquidation); and
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senior staff within our business and IT staff if access to the data is necessary for the performance of their roles, as applicable.
Personal data about other people which you provide to us
If you provide personal data to us about someone else (such as one of your next of kin or, where you are a business, your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without taking any further steps, we may collect, use and disclose that personal data as described or referenced in this Privacy Policy.
You must ensure the individual concerned is aware of the various matters detailed or referenced in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.