Privacy Policy
1. Introduction
This privacy policy is about how the Cultivate Natural Health collects, processes, stores and shares clients data.
This Privacy Policy only relates to personal data collected by Cultivate Natural Health via the Cultivate Natural Health website, application forms, emails and telephone calls. Any personal data collected by the Cultivate Natural Health is used in accordance with UK data protection legislation.
Users should be aware that if they access other websites, using the links provided, these are outside our control. If they provide personal data to other companies, the privacy policies of those companies determine the uses to which that information is put and the Cultivate Natural Health Privacy Policy will no longer apply.
2. The Data Protection Bill 2017
Cultivate Natural Health complies with the principles of the Data Protection Bill 2017 in accordance with General Data Protection Regulations (GDPR).
3. Purpose of data
The data we collect from members is the data required to provide professional services to members, communicate with members and validate and verify the legitimacy of clients. The data held by Cultivate Natural Health is collected at the time of application by members and includes name, surname, home address, clinic address, email, phone number(s), website, certificates of qualifications and records of continued professional development.
4. Disclosures - Sharing of data
We may disclose your personal information (including to trusted third parties) for the purposes for which is primarily held or for a related secondary purpose and in some cases we may disclose information without your consent. Your personal and sensitive information may be disclosed to Cultivate Natural Health employees, Cultivate Natural Health representatives, service providers we use to deliver aspects of our service such as database or email software facilities.
Data is shared via member numbers with insurance providers for the purposes of verifying the legitimacy of insurance applicants.
Data is shared upon request on behalf of a member with external companies that provide practitioner services to verify qualification and status claims.
Data is shared with our regulator the General Naturopathic Council for the purposes of registering practitioners on a public register, and confirming their status as a fully qualified, voluntarily regulated practitioner.
Data is shared internally with administrators for the purpose of verifying payments and refunds.
5. Legacy data
Applicants to Cultivate Natural Health accepted or otherwise are kept on record for up to 3 years. Applicants who have been barred, banned or otherwise excluded from membership are kept on record to prevent renewed access to the Association in keeping with the interests of public safety.
6. Device specific data
The following information may be collected through your device and browser:
Your devices IP address (collected and stored in an anonymized format)
Your email address including first name and surname
Device screen size
Device type (unique identifiers) and browser information
Geographic location (country only)
Preferred language used to display the webpage
7. Digital Log data
Our servers automatically record information which is created using our software. Data includes:
Referring domain
Pages visited
Geographic location (country only)
Preferred language used to display information
Date and time when pages were accessed or created
8. Consent
Cultivate Natural Health membership is an optional process. By joining Cultivate Natural Health members consent via their application to receive information relating to the activities of Cultivate Natural Health in the form of newsletters, regulatory updates, upcoming seminars, webinars, events, training, special offers and information relevant to the profession.
9. Opting out
Opt out mechanisms are in place on all Cultivate Natural Health mailings and communications. Users can choose to opt out at any time by clicking the opt-out button at the bottom of mailings or emailing Cultivate Natural Health directly with a request to opt out.
10. Use Made of Personal Information
Personal information provided to t Cultivate Natural Health will be used for the purposes of providing services to our members. Any personal information which is collected by Cultivate Natural Health will be used by Cultivate Natural Health only in accordance with current data protection legislation.
In addition, personal information may be used for statistical analysis.
Personal data will be collected and processed by Cultivate Natural Health for the following purposes:
(1) To process your membership/consultations
(2) Administration
(4)To validate and confirm your rights to access free and discounted offers with external companies
(8)To record complaints or misdemeanours.
Processing personal data for the above purposes may entail sharing the information with employees, contractors, agents and professional advisors and regulators of the Cultivate Natural Health
Written agreements exist between the Cultivate Natural Health and such parties that there must be no further disclosure of such personal data.
11. Consent
By providing personal data to Cultivate Natural Health users consent to the processing of such data by Cultivate Natural Health as described in this Privacy Policy.
13. Storage of personal data
Data is stored in a secured, encrypted, cloud based database. Payments are processed according to the requirements of 12.9 PCI DSS v3.2 in accordance with PCI security standards.
14. Processing of data
Personal and financial data is processed and handled via Amazon Web Services (AWS), the world’s largest cloud provider with recognised certifications and audits PCI DSS Level 1, ISO 27001, FISMA Moderate, FedRAMP, HIPAA and SOC 1, SOC 2 and SOC 3 audit reports.
All personal data is fully backed up and stored in highly secure AWS data centres with 24/7 infrastructure monitoring, with immediate notification and recovery in place in the event of a data breach.
PayPal is used to process payments for memberships and sponsorships. All PayPal transactions are subject to the PayPal privacy policy. All data handled by PayPal is handled securely by a single data controller for administrative purposes.
15. Cookies
A “cookie” is a small text file that is placed on a user’s computer hard drive by a website. There are several types of cookie and the most common are often referred to as ‘session’ cookies. These are used to keep track of information needed by a user as they travel from page to page within a website. These cookies have a short lifetime and expire within a few minutes of the user leaving the site.
Other types of cookies can be used to track internet activity after the user has left a website. These are usually sponsored by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are ‘harvested’ and ‘refreshed’ whenever the user visits a page where the same or a similar cookie is being used.
Cultivate Natural Health uses benign, short lived ‘session’ cookies to tell whether a website user has logged in, where to find details that can be used to pre-fill parts of on-line forms and to personalise the user’s visit to the website.
Cultivate Natural Health cookies do not analyse visits to other website or any searches undertaken whilst on the Cultivate Natural Health website.
Internet browsers normally accept cookies by default; however, it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful session cookies. Choose an option that rejects all third party and long lived cookies.
Cultivate Natural Health uses cookie free technology that uses Internet Protocol (IP) information exchanged during the course of normal web activity combined with data enhancement technology to get detailed analytics information.
16. Links to Third Party Websites
This Privacy Policy applies solely to the personal data collected by the Cultivate Natural Health and does not apply to third party websites.
Cultivate Natural Health is not responsible for the privacy policies of third party websites. Cultivate Natural Health advises users to read the privacy policies of other websites before registering any personal data.
17. Security
Cultivate Natural Health holds your personal data in accordance with the security provisions of the UK data protection legislation.
If you have any questions about security please contact Cultivate Natural Health
19. Your rights over your data
You have the right to rectify, amend, correct or erase your data except where there is a legal basis for refusal.