The Health Puzzle

Privacy Policy

Last Updated: January 22, 2024

The Health Puzzle respects your privacy and is committed to protecting your personal data. In order to provide you with the best possible service, we may collect and process your personal data. The purpose of this privacy policy is to help you to better understand how we collect, store, and process this personal data. Please read this Privacy Policy carefully to understand our practices regarding your personal information. By continuing to access or use any of our services, you agree to the terms of this Privacy Policy.

1. Age of consent
2. The type of personal information we collect
3. How we collect personal data
4. How we use personal data
5. Purposes for which we will use your personal data
6. Health and highly personal data
7. User accountability
8. Cookies and similar tracking technology
9. Third-party services
10. What we do not do with your personal information
11. Security 
12. Your legal rights
13. Disclaimers
14. Disclosure
15. Policy changes
16. Governing law
17. Contact information
18. Before enrolling

1. Age of Consent

By using this site & enrolling onto The Health Puzzle's Courses you represent that you are at least 18 years old. The Health Puzzle's products and services are intended for those 18 years and older.

2. The Type of Personal Information We Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. We may process (e.g. collect, use, store and/or transfer) different kinds of personal data about you which we have grouped together as follows:

• Identity Data including your name/s and date of birth.
• Contact information including your billing details, email address and delivery address.
• Financial Data including your bank account and card payment details.
• Transaction Data including details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location you use to access this website.
• Profile Data includes your purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.

If we ask for your personal information for a secondary reason, like marketing or providing additional services, we will either ask you directly for your expressed consent or provide you with an opportunity to say no.

3. How we collect personal data

To offer and access our services, we need to collect certain personal data from you. Here is a summary of how we collect your personal data:

• We collect your Contact Data, Identity Data and Technical Data about you to provide you with our products and services, for example, to check payments and communicate with you.
• We collect Profile Data to help us to improve our services for you and others.
• Please see third-party services for financial and transactional data information.
• We collect Usage Data, including how you interact with our services. 
• We also collect backend Usage Data, such as, when you visit our products and services, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer’s operating system, location data, and the type of web browser that you are using.
• We also collect Contact Data and Identity Data submitted by you via any messaging or email feature available from any of our services.

This personal data is collected when you sign up for our services, when you access our services or otherwise provide us with the personal data. In some circumstances, when you have given us express permission, we may also use and store your personal data. We use this information to provide and enhance our services (including servicing your account, if applicable), and to answer any questions you may have.

4. How we use personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate business interests (or those of a third party) and your interests. Your fundamental rights do not override these interests.
• Where we need to comply with a legal obligation.

5. Purposes for which we will use your personal data

Here is a list of some of the purposes that we will use your personal data:

• To answer enquiries and questions prior to enrolling on one of our Courses.
• To provide you with access to our Online Courses and its features.
• To send newsletters and birthday messages if you opt into our mailing list.
• To send out products associated with the Course.
• To manage and process payments.
• To send notifications about changes to our terms and conditions, privacy policy and services.
• To administer and protect our business and services
• To improve our website, products/services, marketing, customer relationships and experience

6. Health and Highly Personal Data

During your experience using The Health Puzzle’s Online Courses will never ask you to share with us your highly personal data, this includes data regarding your health status. While we may provide you with downloadable health questionnaires and/or food diaries as part of your course these are for personal and private use only. It is your responsibility to keep the data that you write in any documents relating to this Course private and confidential. 

7. User Accountability

You are responsible for providing accurate, up-to-date and truthful information when interacting with our products and services, including during registration and profile setup.

8. Cookies and similar tracking technology

We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customise our website content for you as an individual. 

If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer. For information on how to do this on the browser of your mobile phone, you will need to refer to your handset manual. To learn more about cookies, you can visit www.aboutcookies.org. You will also find details on how to block and delete cookies from your computer as well as more general information about cookies. 

• We use cookies to recognise your device and provide you with a personalised experience.
• We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.
• Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet to serve you targeted ads. For more information about targeted or behavioural advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.
• Opting out: You can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.
• We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
• Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

This data helps us to understand:

• Which pages people visit on the site
• Which internet browsers are being used
• What is popular on the site
• Which interactive tools are used by visitors

You can find out more about Google’s cookies on their privacy policy: http://www.google.com/intl/en/policies/privacy/. You can also install the Google Analytics Opt-out tools in your browser: https://tools.google.com/dlpage/gaoptout. 

9. Third-party services

Our Course and site is hosted by Thinkific Labs Inc. (“Thinkific”). Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall. Please review Thinkific's Privacy Policy (https://www.thinkific.com/privacy-policy/) for more information on their data handling practices. 

If you make a purchase on our site, we use a third-party payment processor, such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information.

Please review Thinkific’s (https://www.thinkific.com/resources/privacy-policy/), Stripe’s (https://stripe.com/gb/privacy) and PayPal’s Privacy Policy (https://www.paypal.com/uk/legalhub/privacy-full) for details on how they handle your data.

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, have their own Privacy Policies in respect to the information we are required to provide to them. For these providers, we recommend that you read their Privacy Policies so you can understand the manner in which your personal information will be handled by these providers.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in England and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our Course website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms and Conditions. 

When you click on links on our Course site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

10. What we do not do with your personal information

We do not and will never share, disclose, sell, rent, or otherwise provide Personal Information to other companies. 

11. Security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

12. Your legal rights

You have the following rights with respect to your personal data:

• The right to request a copy of the personal data which The Health Puzzle holds about you;
• The right to request that The Health Puzzle corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for The Health Puzzle to retain such data;
• The right to withdraw your consent to the processing at any time;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data;
• The right to lodge a complaint with the Information Commissioners Office.

13. Disclaimers

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the website, including the illegal acts of third parties (such as criminal hacking).

14. Disclosure

We may use your personal data if you violate our Terms of Service; where there is an overriding public interest in using the information e.g. to safeguard an individual, or to prevent a serious crime; or where there is a legal requirement such as a formal court order. 

15. Policy changes

We may make updates or modifications to this Privacy Policy from time to time. These updates may reflect changes in our business practices, legal requirements, or the evolving nature of our Courses. We will make reasonable efforts to notify you of any significant changes. Notices may be provided through the Course platform, email, or other communication channels we have on record. We encourage you to review any changes carefully. If you do not agree with the updated Privacy Policy, you have the option to discontinue using our products and services. Changes to the Privacy Policy will not have retroactive application. They will apply only to future interactions.

It is your responsibility to keep your contact information up-to-date and stay informed about any updates by checking the Course platform and your communication channels regularly.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of England.

Any dispute arising under or in connection with this Privacy Policy, including disputes regarding its existence, validity, interpretation, performance, or termination, shall be subject to the exclusive jurisdiction of the courts of England.

By accessing or using our products & services, you agree to submit to the jurisdiction of the courts of England for the resolution of any such disputes.

16.1 Venue

The designated jurisdiction (England) also serves as the venue for any legal proceedings that may arise from the interpretation, enforcement, or breach of this Privacy Policy.

16.2 Conflict of Laws

The choice of jurisdiction and applicable law is intended to provide clarity and predictability in case of legal disputes. In some cases, the choice of law may supersede any conflicting principles or laws of other jurisdictions.

16.3 Consent to Jurisdiction

By using the products and services provided by The Health Puzzle, you consent to the jurisdiction and laws specified in this section for any legal matters that may arise.

16.4. Enforceability

If any part of this Privacy Policy is found to be unenforceable under the laws of the designated jurisdiction, the remaining provisions of the terms will remain in full force and effect.

17. Contact Information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer Miss Josie Shillabeer at [email protected] with the subject line ‘Privacy Policy – Courses’.

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.

18. Before Enrolling

By purchasing our Courses, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

Thank you for choosing The Health Puzzle. We are committed to providing you with a valuable and secure learning experience.