Privacy policy – Megha Talwar

A privacy policy is a legally required document put in place for any businesses that collect any type of personal information from their customers. Since as a business, we require collection of private information from customers, this document aims to provide customers with all the details on what, how, where, when and why that information is collected, used and stored. This document however, does not provide extensive details. If you have further questions, please contact Megha Talwar at meghatalwar2018@gmail.com. The privacy policy is regularly reviewed and updated. LAST UPDATED ON May 2024

Definitions

What is personal information – personal information consists of any information that can be used to identify an individual.

What do we do as a business - Megha Talwar is a qualified registered nutritionist (Atnur), a certified Level 3 personal trainer and she also holds a degree in Psychology (Clinical Psychology). She is registered with the official governing body for Nutrition (Association for Nutrition) and Fitness professions (CIMPSA) in the UK. The services she provides include digital content on her website, social media and coaching app on diet plans, training plans, habit creation, lifestyle recommendations and mindset improvement. The focus of this service is to achieve a wholistically improved health for the customers via implementing smart and sustainable lifestyle strategies to create an overall improved sustainable habits. By using this approach, we aim to help customers that are struggling to start their journey or need guidance in some specific aspects.

What information will be collected - For this business, we will be collecting information such as your name, gender, physical address, phone number, email address, body measurements, personal health goals, payment information, dietary intake, activity levels, lifestyle habits, your personal commitments and priorities etc. This information will be collected when the customers sign up for the service in order to make personalized recommendations. The customers are encouraged to maintain complete transparency regarding their lifestyle choices as the effectiveness of any recommendations made will be impacted by that.

Collecting any sensitive information – We do require sensitive information such as medical history, bloodwork, criminal history, ethnicity, food allergy, food intolerance, personal life commitments, body measurements as the recommendations are personalized which is the nature of the role. You are advised to consult a suitable health professional before following any recommendations. We do not recommend any individual suffering from serious chronic illness or injuries, have severe disability of any form, currently pregnant, senior citizen or children under the age of 18 to follow any of these recommendations. We do not take responsibility for the outcome if you choose to ignore this advice. We will never knowingly request personally identifiable information from anyone under the age of 18. If you are the guardian of a minor and suspect they may have provided us with their personal information, please contact us to have the personal information destroyed immediately. We may also collect information when we invite you to provide information through feedback on features on our website, software and app. We may send out e-mail inviting feedback. We may also ask you for information concerning support of our services. Your response to these communications may require you to submit personal information and opinions.

Technical information that is collected - The information will also be collected when the customers are active on the digital content in order to improve the services we offer. Technical information such as IP address, mobile device identifier, meta data, operating system, browser name/version, the referring web page, requested page is collected. The information is collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users movement on the website, and gathering demographic information. This information is used to help us understand the overall usage pattern of our website, software and app.

Usage tracking – we track the user traffic patterns within the site. However, we do not correlate this tracking with individual users. We use tracking information to determine which areas of our site users engage in and which areas they do not engage in based on traffic to those areas. We do not track what individual users engages in but we track how well each page performs overall. This helps us continue to build a better service for you.

Use of cookies – we do not collect any sensitive information if you browse our website anonymously, we only collect information, if you identify yourself to us when you for example, fill out our contact form, email or call us, sign up to our service or make any payment to us for our services. However, cookies may be used to collect information. The cookie itself does not contain personal information although, it will enable us to relate your use of this site to information that you have specifically and knowingly provided. The only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. We use cookies to track user traffic patterns (as described above). Our advertising system delivers a one-time cookie to better track ad impressions and click rates. You can refuse cookies by turning them off in your browser. If you’ve set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You do not need to have cookies turned on to use this site.

How information will be collected – The personal information collected is provided by the customers themselves with their voluntary subscription. During registration the user is required to supply a username, password, and email address. Other methods used to collect that information include consultation call, customer health history questionnaire, personal goals questionnaire, any emails, by making any payments online, by signing terms and conditions, google forms, website cookies, when the customer contacts us through our website or email, when they sign up to our services, when they interact with us on social media and when they participate in polls and surveys on social media),testimonials (If you provide us with a testimonial, you give us your consent to use your name and photo (if supplied) with the content of your testimonial on our website and or in our marketing materials).

Where the information will be used – the collected information is used to personalize effective recommendations towards the customer based on their goals for a healthier lifestyle as much as possible. The diet and training plans are tailor made based on the personal information provided which improves their effectiveness. We also make payments online where we act as your data controller and processor. We also use information voluntarily given by the customers to enhance their experience on the site to attain a better understanding so we can prepare future content based on the interests of our customers. We may use the information provided to help you sign in with ease, remember information so you will not have to re-enter it. We may use it to provide personalised content and information, provide/improve/test/monitor the effectiveness of our service, monitor metrics such as total number of visitors, traffic, and demographic patterns and diagnose or fix any technological problems.

Why that information is collected – the information is collected to create tailor made programs and recommendations to customers which is the nature of the role. Information is also collected to make any digital transactions possible such as selling our service, registering you as a customer, processing payments, to give you access to the member portal, to contact you, to answer your queries, to notify you about changes to our terms or privacy policy, asking you to leave a review, take a survey or poll, to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to deliver relevant website content, to use data analytics to improve our website/app/programs/services/marketing/customer relationships and experiences and to make suggestions and recommendations to you about goods or services that may be of interest to you.

Where is the information stored – Megha Talwar uses third party software to collect client data. The software being used does have electronic forms that are used to collect and store the personal information but these are encrypted and secure forms. There are several inbuilt features to secure privacy of the information in the coaching software. If you have submitted any forms on the website, that information is not saved unless you sign up to work with the Megha Talwar. Your personal information is stored in a password protected software. The payments are also done through in built third party systems within the coaching software. However, all of the third parties are legally bound to not share any personal information with anyone. The information we receive from you strictly remains confidential and does not get shared with anyone unless you consent to it.

Is the information shared with anyone – we do not actively share any personal information with anyone else. Only Megha Talwar has access to that information in a direct form.

We share information if you - under circumstances where there is an overriding public interest, we may use your personal data. For example, if there is a suspicion of a serious crime committed by you, a court order to share your information or to safeguard an individual from yourself, your personal information may be shared with the police/authorities. Also, if you have made any complaints, your personal information may be given to the official governing body to process the complaint effectively.

Cross border transfer - Using the Internet to collect and process personal information involves the transmission of data on an international basis. We do rely on third-party providers to store the information you have provided to us and your data may cross international borders due to this. You acknowledge that different countries have different rules about personal information protection.

Data protection law - At all times, the personal data is protected with security that is consistent with the requirement of General Data Protection Regulation (GDPR) in regards to data protection as well as our own professional standards and duties.

Do third parties have access to the information – We do not share our client details directly with any third parties, including advertisers, sponsors or partners. We only use softwares to store the information and efficiently run the service.

What are the legal reasons for collecting the data – The legal basis for collecting this information is to provide you with evidence based and personalized recommendations. This is essential as any generic information given to a client does not provide the same results as personalized recommendations do therefore, we have a legitimate reason for enquiring this information from you. Ineffective advise can be detrimental to the health, waste of time and finances. Another reason to acquire your address, name and demographic details is to ensure that we can have a legally binding agreement with you. We also need your bank details to process payments online.

What safeguards are in place to ensure data that identifies me is secure? If your personal data will ever be used to identify you, it will be in accordance to the GDPR and under lawful circumstances. During practicing this service, we follow the common law duty of confidence and will not be sharing your personal information without your consent under any circumstances that do not include serious health concerns or law related matters. We ensure that any information that is shared is kept in secured locations such as laptops with encryptions at rest and transit, data backups, logging, etc), restricted by passwords and firewalls are also used to protect from any viruses.

Opt out options - You can opt-out from our services at any time. There is no agreement holding you in place. The customers are allowed to opt out at any given point without disclosing the reasons behind it.

How long do you hold confidential information for - All the information will be held by Megha Talwar till the duration of the agreement on the software but will be transferred to her laptop for the duration specified by AFN (the official governing body) in case of any complaints being made by you. The information would be helpful for the association to investigate the matter fairly. If the client requests, the personal information given by the client will be deleted from the software after the agreement has ended. The information is destroyed after a year of the termination of the subscription. The legal basis for holding your personal data is simply for contract administration.

DISCLAIMER: While we do our best to ensure the security of your data, no method of transmission over the Internet or method of electronic storage can be 100% secure. Despite our efforts, we cannot guarantee the security of your data. Provided we have acted in accordance with this policy, we are not responsible for any loss you may suffer if your personal information has been unlawfully accessed. Although, we do our best to ensure your data is protected to a similar standard as set out in this privacy policy by using reputable third-party providers with similar privacy protections, we cannot always guarantee the quality of third party services. By using our services, you agree to us transferring your personal information to third parties.

Complaints – if you have any complaints, you can contact meghatalwar2018@gmail.com and she will get back to you as soon as possible. Other than that, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). She would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact her first if possible. AFN and CIMPSA are the governing bodies you need to complain to if you are not satisfied with the service. However, if you do not have a strong case where there was no breach of contract from the end of Megha Talwar, she will also allowed to take legal action against you for the harassment.

Data protection officer - As of 1st May 2024, the law relating to data protection in the UK is governed by the Data Protection Act 2018.

What are your rights - Your rights as a customer include being able to request to see, amend or delete your data at any given point. You do not need any reasons to make this request. You can request to have a copy of your personal data at any point. In order to get a copy or access, you simply need to send a written email requesting so at meghatalwar2018@gmail.com. You will be sent a response within 7 working days. You have the right to object in regards to the processing of your personal data at any given point.

As a customer, you hold the right to object towards any data portability, you have the right to complain in regards to any matter you may feel affected by, you have the right to not be subjected to automated decision making by opting out of the services, you have the right to restrict any processing of your personal data, you have the right to be forgotten at any time, you have the right to be informed regarding any information that you may desire to have in regards to the services and products we provide, you have the right of access to the content as long as you meet the requirements set by the Megha Talwar and you also hold the right to request any rectification of your personal data at any given point. The users have the right to have complete confidentiality towards any information that they provide. The information will not be disclosed to anywhere. However, you will need to provide proof of your identity to exercise these rights and we will also store a copy of your proof of identity with our stored information.

By using this site or our services, you automatically consent to the collection and use of your personal information by Megha Talwar in accordance with this privacy policy. If you do not agree, you must stop using our website or the offered services.

CONSENT - It will be understood that by agreeing to these terms and conditions, you give your consent towards respecting them. The client has the right to withdraw consent.

Privacy policy will be updated when any new technology or strategies are implemented, any data breach occurs due to any reason, new regulation laws are introduced and any potential threats are identified that could threaten the privacy of the customers. The privacy policy will be reviewed every 6 months other than that.