Privacy Policy

Last updated: September 2026

1 — Scope

This document refers to personal data, which is defined as information concerning any living person that is not already in the public domain. The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, together with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of data subjects in the United Kingdom. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data, and the lawful, secure storage of personal data.

2 — Who we are

Habitude Limited (hereafter, for the purposes of this privacy policy, referred to as Habitude) is a registered company in England and Wales under registration number 9953299. Its registered office, and the address for written correspondence, is OC Accountancy Ltd, A05 Towngate Works, Dark Lane, Mawdesley, Ormskirk, Lancashire, L40 2QU, United Kingdom. Consultations are held at our trading address: HCA Outpatients, 32 Wimpole Street, London, W1G 8GT.

Habitude provides nutritional therapy, functional medicine consultations, executive coaching, and corporate workshops and keynotes, along with related health and wellbeing services. Services are carried out in accordance with the guidelines and codes of conduct of the practitioner's affiliated professional bodies, where these exist. Details of our services can be found on our website or can be provided on request.

3 — Personal Data

(i) For the purposes of providing consultations and personalised health and lifestyle recommendations, Habitude may require detailed health information. We will only collect what is relevant and necessary. When you attend a consultation, we will make notes which may include details concerning your health history, medication, symptoms, nutrition, and other matters affecting your wellbeing. This data is always held securely and is not shared with anyone not involved in providing your consultation, although for data storage purposes it may be handled by pre-vetted staff who have signed an integrity and confidentiality agreement. To be able to process your personal data, it is a condition of any consultation that you give your explicit consent to allow Habitude to document and process your personal health data. Contact details you provide - such as telephone numbers, email addresses, and postal addresses - may be used to remind you of future appointments, outstanding invoices, administrative changes, or to provide reports or other information concerning your care. Where your care would benefit from it, there may be circumstances that require the sharing of your records with other healthcare practitioners, which may include but is not limited to GPs, consultants, and medical insurance companies. Where this is required, we will always inform you first unless we are under a legal obligation to comply.

(ii) For marketing purposes, Habitude may also use the contact details you provide to respond to your enquiries, including making telephone contact and emailing you information which we believe may be of interest to you.

(iii) Habitude does not sell or broker your data. You can ask to be removed from our marketing database at any time by emailing or telephoning us using the contact details provided at the end of this Privacy Notice.

(iv) Some basic personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls, and from details of your visits to our website, including but not limited to personally identifying information such as Internet Protocol (IP) addresses.

(v) The Habitude website (www.habitude.co.uk) is hosted on Wix and uses cookies. A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Cookies help us to identify and track visitors and their website access preferences. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the website. For further information, visit www.aboutcookies.org or www.allaboutcookies.org, which explain how to remove them. However, some website features may not function as a result.

(vi) Habitude will only collect the information needed so that we can provide you with the services you require. The business does not sell or broker your data.

(vii) With your consent, your consultation may be audio-recorded and transcribed using an AI-assisted clinical scribe (Arlo), which integrates with Cliniko, so that a structured draft note of the session can be produced. Habitude also uses an AI tool (Gemini, within Google Workspace) to assist in drafting client summaries, action plans, updates for consultants, and clinical notes. In every case this support is used to produce a first draft only: Hayley reviews, edits, and approves all output and remains responsible for the clinical content of your records. No decision affecting your care is made by AI alone. The legal basis for recording is your explicit consent, which you may withdraw at any time; where you prefer not to be recorded, written notes will be taken instead. Audio recordings are encrypted and are automatically deleted once the note has been generated. Details of where these providers process data, and the safeguards in place, are set out in section 9.

4 — Legal basis for processing any personal data

To meet our contractual obligations, obtained from explicit client consent and legitimate interest — including processing payments and insurance claims on behalf of clients, and responding to enquiries concerning the services provided.

5 — Legitimate interests pursued by Habitude

To promote nutritional therapy, functional medicine, executive coaching, corporate workshops and keynotes, and any other services which benefit the health and wellbeing of our clients.

6 — Consent

By agreeing to this privacy notice, you are consenting to Habitude processing your personal data for the purposes outlined. You can withdraw consent at any time using the postal address or email address provided at the end of this Privacy Notice. However, we reserve the right to process and complete any outstanding payments and to provide information in order to meet any legal obligations.

7 — Disclosure

Habitude will keep your personal information safe and secure. Only staff engaged in providing your consultations will have access to your client records, although our administration team will have access to your contact details so that they can make appointments and manage your account. We may also share, receive information from, or exchange information with (a) other practitioners and providers of services with whom we work in connection with your care, and (b) a third party in the event of a merger, asset sale, or other related transaction.

Habitude will not disclose your personal information unless compelled to in order to meet legal obligations, regulations, or valid governmental requests. The business may also enforce its Terms and Conditions, including investigating potential violations, to detect, prevent, or mitigate fraud or security or technical issues, or to protect against imminent harm to the rights, property, or safety of its practitioners and staff.

8 — Retention Policy

Habitude will keep client files and any additional records (for example, contact details held on a phone) safely, securely, and in good condition for exactly eight years from the date of the client's last consultation, in order to meet its legal and professional obligations. Where the client is a child, these records will be kept until his or her 25th birthday — unless the client was 17 at the conclusion of the nutritional therapy, in which case the records will be kept until their 26th birthday. These timescales continue to apply in the event of a client's death during the required retention period. After the applicable period has elapsed, all personal data will be deleted, unless basic information needs to be retained to meet our future obligations to you, such as erasure details.

9 — Data storage

Client records are currently stored on Cliniko, a cloud-based practice management solution whose servers are based in Australia. To ensure that data processed outside the United Kingdom and the EEA is handled compliantly, Cliniko maintains a Data Processing Addendum, a Privacy Policy, and Terms of Service. Cliniko has appointed a Data Protection Officer, who oversees its compliance with data protection law, advises on its obligations, and acts as a contact point for data subjects and supervisory authorities. The Data Protection Officer is contactable at dpo@cliniko.com.

Cliniko has also appointed an EU Representative, a company called VeraSafe. VeraSafe can be reached via their website (https://www.verasafe.com/privacy-services/contact-article-27-representative/), at article27@verasafe.com, or by postal mail at:

VeraSafe Czech Republic s.r.o, Rohanské nábřeží 678/23, Prague 8, 18600, Czech Republic

VeraSafe Ireland Ltd, Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland

Where consultations are recorded and transcribed, this is carried out using Arlo, an AI clinical scribe that integrates with Cliniko. Audio is encrypted in transit and at rest and is automatically deleted once the note has been generated. Arlo does not use client recordings or data to train AI models, and processes data within the United Kingdom. The resulting draft note is synced to Cliniko, where it is held under the arrangements described above.

AI-assisted drafting of client summaries, action plans, consultant updates, and clinical notes is carried out using Gemini, provided within Habitude's Google Workspace (Business Plus) subscription. Google Workspace incorporates Google's Data Processing Addendum, meeting the Article 28 requirement under UK GDPR, which binds Google to process data strictly on Habitude's instructions. Business prompts, files, and outputs are not used to train AI models outside Habitude's domain, nor are they reviewed by human evaluators. Where data is transferred outside the United Kingdom, transfers are safeguarded by Standard Contractual Clauses and the UK International Data Transfer Addendum embedded within the Workspace terms. Gemini respects existing Workspace access permissions and will not surface information to anyone who is not already permitted to view it, supporting data security under Article 32 of UK GDPR.

Data will always be stored in a safe manner and in accordance with UK GDPR rules.

10 — Your rights as a data subject

At any point whilst Habitude is in possession of, or processing your personal data, all data subjects have the following rights:

Right of access - you have the right to request a copy of the information that we hold about you.
Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing - where certain conditions apply you have a right to restrict the processing.
Right of portability - you have the right to have the data we hold about you transferred to another organisation.
Right to object - you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling - you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Habitude refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request, Habitude can confirm what information it holds about you and how it is processed.

11 — You can request the following information:

Identity and the contact details of the person or organisation (Habitude) that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Habitude and information about these interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn't collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

12 — To access what personal data is held, identification will be required

Habitude will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate, and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Habitude is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to hello@habitude.co.uk, or by writing to us at the address below.

13 — Links to other sites

This Privacy Policy applies only to our site. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website. You should check that policy before continuing to access the link.

14 — Changes to the Privacy Policy

We may update this policy from time to time by publishing a new version on our website and making a copy available on request. You should therefore check our Privacy Policy periodically to ensure that you are happy with any changes.

15 — Complaints

Habitude is regulated by the Information Commissioner's Office (ICO), which is responsible for regulations that cover the collection, storage, processing, disclosure, transfer, and destruction of personal data in the United Kingdom, and we are registered with them as a data controller under registration reference ZB253065.

In the event that you wish to make a complaint about how your personal data is being processed by Habitude, you have the right to complain to us. If you do not receive a response within 30 days, you can complain to the ICO.

The details for each of these contacts are:

Hayley Paul, Director, Habitude Limited, OC Accountancy Ltd, A05 Towngate Works, Dark Lane, Mawdesley, Ormskirk, Lancashire, L40 2QU, United Kingdom. Email hello@habitude.co.uk

ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone +44 (0) 303 123 1113 or via https://ico.org.uk/global/contact-us/email/.