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HomePrivacy Policy

Introduction

We are Fresh Start Lifestyles, LLC, a company incorporated in Memphis, Tennessee USA. Our company number is EIN 84-4081070 and our registered office is at Floor 27, 5100 Poplar Ave, Memphis, TN 38137, USA.

We are committed to ensuring that your privacy is protected and we strictly adhere to the provisions of the USA GDPR (USA General Data Protection Regulation), together with the Data Protection Act 2018, any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the USA, and any successor legislation to GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (Data Protection Legislation).

In order for Fresh Start Lifestyles to provide, our products and services we need to process a certain amount of data, some of which is personally identifiable.

Our Privacy Policy sets out the different kinds of personal data we process, how we collect it, what processing is carried out, who personal data is shared with, how long we keep personal data and how we safeguard it along with details of your rights relating to data protection and how to contact the ICO, the USA’s data protection regulator.

Customers & prospective customers (purchasing via our sales team)

All customers and prospective customers have a record with our CRM database. Along with details about the organization and products purchased, we also store contact information for those people we know at the organization. For customers we process this data in order for us to meet out contractual obligations, for prospective customers our condition for processing is legitimate interest.

Website visitors & online customers

When you place an order with us on our website, we will ask you to provide certain personal information, for example:

  • your name; and
  • your email address.

Please note that we require this information to be able to process your order and fulfil our contractual obligations (our condition for processing under USA GDPR). We may be unable to fulfil the contract without your personal data.

If you purchase services, our third party payment provider (Stripe) will require additional personal information in order to process such payment (e.g. your home address). Please note that this information is not collected or stored by us.

We will share your personal details with a third party in order to enable you to leave the review of our products and services to help us continually improve.

Your personal information will then be used by us to provide you with the services you ordered and to communicate with you regarding the provision of those services. We also monitor website usage and provide statistics to third parties for the purposes of improving and developing our website and the services we provide via our website. Please note that any such statistics and/or information provided to third parties will be made on a confidential basis and will not include information that can be used to identify any individual.

Our use of cookies

A cookie is a small piece of information which is automatically created by our website on your computer. Please note that cookies are harmless to your computer. Cookies are a useful way of remembering the choices you have previously made while visiting our website.

If you don’t want us to use cookies when you use our website, you can adjust your internet browser settings not to accept cookies. Your web browser’s help function should tell you how to do this. Alternatively, you can find out more information about cookies how to manage them on the website: www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

You can find out how to manage cookies on popular browsers by clicking on the links below:

Please note that if you set your computer to not accept cookies, there may be certain features/areas on our website that you may not be able to use. It may be necessary to have cookies enabled in order to purchase or access online courses and materials.

Newsletter/ marketing subscribers

When you fill out a webform to sign up to a newsletter, download a resource, such as an infographic, or enquire about a product, we may ask you to provide certain personal information, including your:

  • name;
  • email address;
  • job title & the organisation you work for; and
  • telephone number.

By completing the form and ticking the relevant boxes you are providing your consent for Fresh Start Lifestyles to process your personal data, and this is the legal basis we are relying on to do so.

We will use the information that you give us to send you relevant emails containing Fresh Start Lifestyles news & marketing communications. Your information will be stored by a third party data processor; Campaign Monitor, whose servers are located in the US.

In addition, if you have enquired about a product or service we will use the information you have given to update our customer relationship management system so one of our consultants or advisors can contact you. 

Some automation and profiling may be used to send emails or a series emails based on your indicated preferences and your interactions with the emails we send to you. For example if you have enquired about a particular product we may send you a series of emails outlining features or benefits of that particular product.

We regularly review your interactions with the emails we send you and remove any subscribers who have shown and extended period of inactivity. You can withdraw your consent and unsubscribe at any time by clicking the link at the bottom our email communications or by emailing this address.

If you continue to interact with our emails or website, we will retain your data indefinitely so we can continue to send you emails.

We will not sell or pass your information to third parties other than those set out above.

How do we safeguard your personal data?

Protecting your security and privacy is extremely important to us and we make every effort to secure your information and maintain your confidentiality in accordance all relevant Data Protection Legislation. Our systems are protected by various levels of security technology, which are designed to protect your information from any unauthorized or unlawful access, processing, accidental loss, destruction and damage.

Please note that we may need to disclose your personal information where we:

  • are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
  • need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organizations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.

Your rights

The USA GDPR provides you with the following rights:

The right of access

You can ask us to confirm that we process your personal data and provide access to and copies of the information we hold about you by contacting us at freshstartlifestyles@gmail.com. We will process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request, unless there are extenuating circumstances. If we need more information to comply with your request, we’ll let you know.

The right to rectification

If you believe personal data we hold about you is inaccurate or incomplete, or any of the information you provide to us changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us at freshstartlifestyles@gmail.com

We will comply with your request within one month of receiving it, unless we don’t feel its appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.

The right to erasure

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

  • where we no longer need your personal data for the purpose for which we collected it;
  • where we have collected your personal data on the grounds of consent and you withdraw that consent;
  • where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
  • where we have unlawfully processed your personal data (i.e. we have failed to comply with USA GDPR);
  • where the personal data has to be deleted to comply with a legal obligation; and
  • where the personal data we process relates to the offer of online services to a child.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.

To request that your information is deleted, please contact us at freshstartlifestyles@gmail.com

The right to restrict / object to processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

  • if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
  • if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
  • if the processing is unlawful; or
  • if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

You are entitled to object to us processing your personal data:

  • if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
  • for direct marketing purposes (including profiling); and/or
  • for the purposes of scientific or historical research and statistics.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defense of legal claims.

If you wish to restrict or object to the processing of your information, please contact us at freshstartlifestyles@gmail.com

The right to data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:

  • to personal data you provide to us;
  • where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
  • where we carry out the processing by automated means.

If you wish to restrict or object to the processing of your information, please contact us at freshstartlifestyles@gmail.com.

Rights in relation to automated decision making and profiling

Automated decision making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).

We carry out automated decision making using your personal data as detailed under the Newsletter / Marketing Subscribers heading above.

Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. This privacy policy applies solely to information collected on our website.

Please note that we may change our Privacy Policy from time to time. If we make any changes, these will be shown on our website and will immediately supersede any previously posted information.

We have appointed a Data Protection Lead who is responsible for overseeing questions in relation to this privacy notice and is monitoring and leading on data protection and USA GDPR compliance. If you have any queries or comments about this Privacy Policy, including any requests to exercise your legal rights, please contact our Data Protection Lead either via an email to: freshstartlifestyles@gmail.com or write to us at Fresh Start Lifestyles, Floor 27, 5100 Poplar Ave, Memphis, TN 38137, USA. We always welcome your views about our website and our Privacy Policy.

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