Ravi Summan Wellness Limited: Privacy Notice

This Privacy Notice sets out how we collect, use, maintain and disclose Personal Data, including any information provided through our website (the “Website”).

Your privacy is of the utmost importance to us. Please read this Privacy Notice carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Whenever you provide Personal Data, we are legally obliged to use it in accordance with the laws concerning the protection of Personal Data.

Who we are

RAVI SUMMAN WELLNESS LIMITED is a company incorporated and registered in England and Wales with company number 12373717 whose registered office address is 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ (“Ravi Summan Wellness Limited”)

For the purposes of the Data Protection Act 2018, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Ravi Summan Wellness Limited will be the ‘data controller’ for all Personal Data that we determine the means and purpose of processing. We are registered with the Information Commissioner’s Office under registration number ZA787452.

By “Personal Data” we refer to information collected or held by Ravi Summan Wellness Limited, that identifies and relates to you as an individual.

Information we may collect

We may collect Personal Data about you when you request our services or engage us through the Ravi Summan Wellness Limited website, through social media platforms or via telephone calls or online video consultations, including:

• your name;
• title;
• date of birth;
• ethnicity;
• gender;
• GP details;
• next of kin;
• details of your health and lifestyle, including, height, weight, body measurements, photos to track start and end progress for our services, details on our Physical Activity Readiness Questionnaire (PAR-Q) form of your current health status and details of any injuries or conditions (it being acknowledged that the PAR-Q form is not limited to physical activity, but also includes personal development services);
• postal address;
• invoicing details/address;
• information regarding the services you request;
• supplementary information you provide us about yourself when contacting us;
• email address;
• social media links;
• telephone numbers (including mobile); and
• payment details (where you pay by card).

We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

What do we do with the information we collect?

We will use your Personal Data for a number of purposes including:

• to liaise with you in relation to the sessions provided through our services, which include the provision of personal fitness training, nutrition, diet advice and wellness services, personal development, leadership training and lifestyle coaching;
• to plan your service programme;
• internal record keeping;
• to give you information that you request from us and to improve our services;
• to notify you about changes to our services;
• to allow us to operate the Website efficiently;
• to ensure that the content from our Website is presented in the most effective manner for you and your computer;
• any relevant troubleshooting, testing or statistical analysis as appropriate; and
• to keep the Website secure.

Where we have your permission to do so, we may also use the information collected to:

• provide you with information about our services that we offer via promotional communications; and
• keep you up to date with features on the Website,

however, you can opt-out of any of these data uses at any time by emailing info@ravisumman.com.

Data retention

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.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where you have engaged us to provide you with services, our standard approach is to delete any Personal Data relating to you upon the fulfilment or termination of the services.

Legal basis of processing

We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the contractual services you have requested from Ravi Summan Wellness Limited or if you have provided us with adequate consent to process your information for other purposes.

If we choose to process your information under the legal basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@ravisumman.com.

Protecting your information

We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.

However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.

Transfer of data outside of the EU

We do not currently transfer any Personal Data outside of the European Economic Area.



Should this change, we will ensure that there are adequate safeguards in place to protect your Personal Data, which provide enforceable legal remedies and rights over your Personal Data equivalent to those under the applicable Data Protection Legislation.

Sharing your information with others

Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies.

However, sometimes we may share your information with third parties in the following ways:

• we may use carefully selected sub-processors to help us collect, store or manage your information (these include email providers, payment processors and our CRM provider, VCITA). This will be managed under the terms of a data processing agreement;
• where you have a requirement to discuss personal development and leadership training, your details would be shared with the following consultant partners: The New Leadership or Nya Ledarskapet. The New Leadership or Nya Ledarskapet provides change management consulting, leadership and personal development training to organisations, corporates and individuals. Further details can be found at: http://www.thenewleadership.com. Their company details are as follows: Nya Ledarskapet Norden AB (The New Leadership Nordic AB), company registration number from Sweden: 556787-3038;
• we may share your progress photos on our Website and/or social media platforms with your prior consent;
• analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
• if Ravi Summan Wellness Limited is acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets. We process your Personal Data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

Access to your Personal Data

You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting Ravi Summan Wellness Limited.

The information you request must relate to you or another person that you have authority to act on their behalf. Ravi Summan Wellness Limited will require a confirmation of your ID (consisting of photo identification and proof of address) prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, Ravi Summan Wellness Limited reserves the right to refuse your request for access to Personal Data. The rights you have in relation to the Personal Data we hold regarding you are:

• the right to rectify any inaccuracies in the information we hold;
• the right to erasure of information in specific circumstances;
• the right to request transfer of your information to another controller; and
• the right to object to processing in certain circumstances.

If you have provided us with consent to process your information, you always reserve the right to withdraw this consent via the method detailed in the paragraph below. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, Ravi Summan Wellness Limited will immediately cease processing the information in question.

Please send your request to Ravi Summan Wellness Limited by emailing info@ravisumman.com. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Notice

We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data.

Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the 'Last updated' section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.

We recommend that you print a copy of this page for your reference.

Cookies

This Website uses cookies to help us recognise different users of the Website and to provide users of the Website with a good experience when using it. Please see the Cookies notification on the Website for further information.

How can you make a complaint?

New ParagraphPlease note that if you are not satisfied with the processing of your Personal Data as set out in this Privacy Notice, please contact us at info@ravisumman.com.

You have the right to issue a complaint directly with the Information Commissioner’s Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).

Contacting us

Please contact us at info@ravisumman.com] if you have any questions, comments or requests regarding this Privacy Notice.

Last updated September 2020