Privacy Policy

For data-protection purposes, the data controller is:

Dr Surinder Sandhu trading as Empowered Wellness Coach

Email:

hello@empoweredwellnesscoach.co.uk

Empowered Wellness Coach is not presented as a registered limited company.

Depending on how you interact with us, we may collect:

• your name;
• email address;
• telephone number;
• information submitted through enquiry or consultation forms;
• information contained in correspondence with us;
• information about your health, wellbeing, lifestyle, concerns or goals that you choose to provide;
• information reasonably required to administer the Empowered Wellness Coach programme;
• technical, security and website-use information where applicable.

Information concerning physical or mental health may constitute special-category personal data and receives additional protection.

We may process personal information in order to:

• respond to an enquiry or request made by you;
• arrange a Free 15–30 minute confidential consultation with Dr Surinder Sandhu;
• assess potential suitability for the Empowered Wellness Coach programme;
• take steps requested by you before entering into a service relationship;
• provide and administer services that you choose to receive;
• communicate with you about those services;
• maintain appropriate administrative records;
• protect the security and integrity of our website and systems;
• prevent misuse or fraud;
• meet applicable legal, regulatory or professional responsibilities.

Where processing is necessary to respond to your request, arrange a consultation, assess suitability, enter into or administer an agreed programme or service, we may rely upon Article 6(1)(b) UK GDPR, where applicable.

For proportionate security, fraud prevention, administration and protection of legitimate business interests, we may rely upon legitimate interests where those interests have been assessed and do not override your rights and interests.

Health information is treated with additional care.

Where health or other special-category personal data is voluntarily provided through the general Empowered Wellness Coach wellness website or programme, we will only process that information where:

1. an appropriate Article 6 lawful basis applies; and
2. an appropriate Article 9 condition applies.

For general EWC wellness-programme health information, this may include Article 9(2)(a) explicit consent, where valid explicit consent has been obtained.

Health-data consent must be separate, specific, explicit and appropriately recorded.

We do not assume that Article 9(2)(h) healthcare processing automatically applies to the general EWC wellness programme.

Where Dr Surinder Sandhu separately acts within his regulated chiropractic professional scope, different professional and legal obligations may apply to that specific activity.

If you request a consultation, information you provide may be used to arrange and conduct a:

Free 15–30 minute confidential consultation with Dr Surinder Sandhu.

The purpose of the consultation is to discuss your circumstances, goals, potential suitability and possible next steps.

Where you participate in the 12-week Empowered Wellness Coach programme, we may process information reasonably required to deliver and administer the service.

Any health-related information will be processed only where an appropriate lawful basis and special-category condition apply.

Marketing communications are separate from service administration and health-data processing.

Where consent is required for marketing, it must be:

• freely given;
• specific;
• informed;
• separate from other permissions;
• capable of being withdrawn.

Marketing consent must not be bundled with health-data consent or made a condition of receiving a service where it is not necessary.

The EWC website/application uses Base44 as a website/application platform.

We may also use appropriately selected providers for functions such as email, booking, data storage, communications or other operational services.

Only verified providers actually in use should be identified in public-facing legal information.

Where a provider processes personal information on our behalf, appropriate contractual and data-protection arrangements must be in place where required.

Some technology providers may process personal information outside the United Kingdom.

Where this occurs, we will use appropriate safeguards where required by applicable data-protection law.

Any public description of international transfers must reflect the providers and safeguards actually in use.

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, contractual, regulatory, accounting, security or professional requirements.

Our current operational retention approach is:

• unsuccessful enquiries and consultation leads: generally up to 12 months after the last meaningful contact;
• marketing records: until consent is withdrawn, the information is no longer required, or an appropriate periodic review determines that continued retention is unnecessary;
• programme-client administrative records: generally up to 6 years after the service relationship ends, where justified for contractual, accounting or legal purposes;
• EWC health/wellness information: reviewed when the programme ends and generally retained for no longer than 3 years after the relationship ends, unless a specific legal, regulatory or professional reason requires longer;
• routine security/system logs: generally 30–90 days, unless a longer period is demonstrably necessary for security, investigation or legal purposes.

These periods are operational retention decisions and should not be interpreted as statutory retention periods unless expressly stated otherwise.

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

No internet-based service can guarantee absolute security.

The website must accurately disclose the cookies and similar technologies actually in use.

Non-essential analytics, advertising pixels or similar tracking technologies must not be activated before any consent required by applicable law has been obtained.

Continuing to browse the website must not by itself be treated as consent to non-essential tracking.

Any marketing opt-in must remain separate and unticked by default where consent is required.

Depending on the circumstances, you may have rights relating to:

• access to your personal information;
• correction of inaccurate information;
• deletion;
• restriction of processing;
• objection;
• portability;
• withdrawal of consent where processing relies upon consent.

Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

Requests may be sent to:

hello@empoweredwellnesscoach.co.uk

You may also have the right to raise a concern with the UK Information Commissioner’s Office.

We may update this Privacy Policy where our services, technology, processing activities, legal requirements or trading structure change.

If the legal or trading structure of Empowered Wellness Coach changes, this Privacy Policy must be reviewed and updated before, or at the same time as, that change takes effect.