1. Data Controller Information
The data controller responsible for your personal data is:
Flushingeliminat
87-135 Brompton Rd
London SW1X 7XL
United Kingdom
Email: hello@flushingeliminat.world
Telephone: +44 20 7730 1234
For any data protection enquiries, please contact us using the details above. We aim to respond to all data subject requests within one calendar month, as required by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Scope of This Policy
This Privacy Policy applies to all personal data collected through our website at flushingeliminat.world, including when you browse our pages, submit contact forms, enrol in sleep readiness programmes, purchase readiness plans, or interact with our cookie consent mechanisms. It does not apply to third-party websites that may be linked from our pages, and we encourage you to review the privacy policies of any external sites you visit.
We are committed to processing personal data lawfully, fairly, and transparently. This policy is designed to provide you with clear information about what data we collect, why we collect it, how long we retain it, and what rights you have in relation to your data.
3. Personal Data We Collect
3.1 Data You Provide Directly
When you interact with our website or services, you may voluntarily provide the following categories of personal data:
- Identity data: Your full name as submitted through contact forms or programme enrolment.
- Contact data: Your email address, telephone number, and postal address when provided.
- Communication data: The content of messages you send us via contact forms, email, or telephone.
- Programme data: Information you provide during readiness plan assessments, including evening habit descriptions, schedule details, living environment notes, and stated goals.
- Consent records: Your preferences regarding data processing, marketing communications, and cookie usage.
- Transaction data: Payment-related information processed through our payment providers when you purchase programmes or plans. We do not store full payment card details on our servers.
3.2 Data Collected Automatically
When you visit our website, certain technical data may be collected automatically through cookies and similar technologies, subject to your consent preferences:
- Technical data: IP address, browser type and version, operating system, device type, and screen resolution.
- Usage data: Pages visited, time spent on pages, navigation paths, referral sources, and interaction patterns.
- Location data: Approximate geographic location derived from your IP address (country and city level only).
For detailed information about cookies and similar technologies, please refer to our Cookie Policy.
4. Purposes and Legal Bases for Processing
We process your personal data only where we have a valid legal basis under the UK GDPR. The table below outlines our primary processing activities:
- Responding to enquiries: When you contact us, we process your name, email, and message content to respond to your request. Legal basis: legitimate interests (operating our business and communicating with prospective clients) or consent (where you have explicitly agreed to data processing via our contact form checkbox).
- Delivering programmes and plans: We process assessment data and consultation notes to create and deliver your sleep readiness programme or personalised plan. Legal basis: performance of a contract.
- Payment processing: Transaction data is processed to complete purchases. Legal basis: performance of a contract and legitimate interests.
- Website analytics: Usage data is processed to understand how visitors interact with our site and to improve user experience. Legal basis: consent (analytics cookies are only activated with your permission).
- Marketing communications: Where you have opted in, we may send informational updates about our programmes. Legal basis: consent. You may withdraw consent at any time.
- Legal compliance: We may process data to comply with legal obligations, including tax record-keeping and responding to lawful requests from authorities. Legal basis: legal obligation.
- Security and fraud prevention: Technical data may be processed to protect our website and services from unauthorised access and abuse. Legal basis: legitimate interests.
5. Data Sharing and Third Parties
We do not sell your personal data to third parties. We may share your data with the following categories of recipients where necessary for the purposes described in this policy:
- Service providers: Companies that provide hosting, email delivery, payment processing, analytics, and customer relationship management services on our behalf. These providers act as data processors and are contractually bound to protect your data.
- Professional advisers: Legal, accounting, and auditing professionals who assist us in operating our business, subject to confidentiality obligations.
- Regulatory authorities: Where required by law, regulation, or legal process.
Any international transfers of personal data outside the United Kingdom are conducted with appropriate safeguards in place, such as Standard Contractual Clauses approved by the Information Commissioner's Office (ICO), or transfers to countries with adequacy decisions.
6. Data Retention Periods
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law:
- Contact form submissions: Retained for twenty-four months from the date of submission, unless an ongoing business relationship develops.
- Programme and plan records: Retained for six years from the date of last interaction, in line with UK business record-keeping requirements.
- Payment and transaction records: Retained for seven years in accordance with HMRC requirements.
- Cookie consent records: Retained for the duration of the consent period (up to twelve months) plus an additional twelve months for audit purposes.
- Analytics data: Aggregated and anonymised data may be retained indefinitely. Identifiable analytics data is retained for twenty-six months.
- Marketing consent records: Retained for as long as consent is active, plus twelve months after withdrawal for compliance verification.
When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be associated with you.
7. Data Security Measures
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- HTTPS encryption for all data transmitted between your browser and our servers.
- Access controls limiting personal data access to authorised personnel who require it for their role.
- Regular security assessments of our website infrastructure and third-party service providers.
- Encrypted storage for sensitive programme assessment data and consultation records.
- Staff training on data protection principles and secure data handling practices.
- Incident response procedures for detecting, reporting, and investigating personal data breaches.
While we take reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. We encourage you to use strong passwords and exercise caution when sharing personal information online.
8. Your Rights Under UK GDPR
As a data subject, you have the following rights in relation to your personal data:
- Right of access: You may request a copy of the personal data we hold about you.
- Right to rectification: You may request correction of inaccurate or incomplete personal data.
- Right to erasure: You may request deletion of your personal data where there is no compelling reason for continued processing.
- Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
- Right to data portability: You may request your data in a structured, commonly used, machine-readable format where processing is based on consent or contract and carried out by automated means.
- Right to object: You may object to processing based on legitimate interests or for direct marketing purposes.
- Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
- Right to lodge a complaint: You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data protection rights have been violated.
To exercise any of these rights, please contact us at hello@flushingeliminat.world. We will respond within one calendar month. In complex cases, we may extend this period by a further two months and will inform you of the extension and reasons.
9. Children's Privacy
Our website and services are intended for adults aged eighteen and over. We do not knowingly collect personal data from individuals under the age of eighteen. If we become aware that we have collected data from a minor without appropriate parental consent, we will take steps to delete that information promptly. If you believe a minor has provided us with personal data, please contact us immediately.
10. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you. Any personalised readiness plans are created by human advisors based on information you provide, supplemented by structured programme frameworks. Technology assists in organising and presenting information but does not make autonomous decisions about your programme content.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will update the date at the top of this page and, where appropriate, notify you via email or a prominent notice on our website. We encourage you to review this policy periodically.
12. Contact Us
If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:
Flushingeliminat
87-135 Brompton Rd, London SW1X 7XL, United Kingdom
Email: hello@flushingeliminat.world
Telephone: +44 20 7730 1234