The short version: we only use personal information where we have a clear reason to do so. We do not sell your information. Health and treatment records receive additional protection because they are particularly sensitive.
01
Who we are
HUMAN UPGRADE LTD operates The Linford Method and the Amy Linford website and clinic services. HUMAN UPGRADE LTD is the data controller for the personal information described in this policy.
Company number: 16335514
Address: Ash Cottage, St James Road, Sway, Lymington, Hampshire, SO41 6AN
Privacy email: fitaj@hotmail.co.uk
In this policy, “we”, “us” and “our” mean HUMAN UPGRADE LTD, trading through The Linford Method.
02
Information we collect
Depending on how you interact with us, we may collect:
- your name, date of birth and contact details;
- appointment, payment and transaction information;
- health history, symptoms, medication, injuries, treatment notes, assessments, progress and relevant lifestyle or activity information;
- communications, enquiries, feedback and preferences;
- emergency contact and GP or other healthcare-professional details where relevant;
- marketing choices and a record of consent or opt-out;
- technical information such as IP address, browser, device, pages visited and cookie choices; and
- information you choose to provide through Zanda forms, email, telephone, the website or during an appointment.
We normally collect information directly from you. Where appropriate and with a suitable basis, we may also receive information from a parent or representative, a referrer, insurer or healthcare professional.
03
How and why we use it
| Purpose | UK GDPR lawful basis |
|---|---|
| Responding to enquiries, arranging appointments, delivering services, taking payment and managing our relationship with you | Contract, or steps requested before entering a contract |
| Keeping appropriate treatment and business records, handling complaints and establishing or defending legal claims | Legitimate interests and, where applicable, legal obligation |
| Maintaining safety, quality, security, fraud prevention and service administration | Legitimate interests and, where applicable, legal obligation |
| Sending marketing communications | Consent or, where all legal requirements are met, legitimate interests and the PECR “soft opt-in” |
| Measuring and improving the website using non-essential analytics | Consent |
Where we rely on legitimate interests, those interests include operating and improving the business, providing a safe and effective service, protecting our legal position and keeping proportionate records. We consider the effect on your rights before relying on this basis.
04
Health information
Health information is special category personal data and receives additional protection. We use it only where we have both an Article 6 lawful basis and an Article 9 condition under the UK GDPR.
For treatment and assessment records, we generally rely on your explicit consent under Article 9(2)(a). Where necessary, we may also process relevant information for the establishment, exercise or defence of legal claims under Article 9(2)(f).
You may withdraw consent by contacting us, but this will not make earlier use of your information unlawful. We may still need to retain certain records where another lawful basis or legal reason applies. If the information is necessary to provide a safe service, withdrawing consent may mean that we cannot continue treatment.
05
Who we share information with
We share only what is reasonably necessary. Recipients may include:
- Zanda, which provides our booking, forms, client-record and email systems;
- Leadpages, which hosts and operates parts of our website;
- Google Analytics, where you consent to analytics;
- Usercentrics/Cookiebot, which records and manages website cookie choices;
- payment, accounting, IT, professional-adviser and secure communications providers;
- healthcare professionals, referrers or insurers where you ask us to share information or another lawful basis applies; and
- regulators, courts, law-enforcement bodies or other parties where disclosure is required or legally justified.
Service providers acting on our instructions must handle information securely and only for agreed purposes. We do not sell or rent personal information.
06
International transfers
Some technology providers may store or access information outside the UK. Where this happens, we take steps designed to ensure an appropriate level of protection, such as using a country covered by UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses, or another lawful safeguard.
You may contact us if you would like more information about the safeguards relevant to your information.
07
How long we keep information
We keep information only for as long as needed for the purpose for which it was collected and to meet legal, insurance, tax and professional obligations. Our usual periods are:
- adult treatment and health records: eight years after the last appointment;
- financial and transaction records: six years after the relevant financial year;
- unsuccessful or general enquiries: normally up to 12 months after the last contact;
- marketing records: until you opt out or we determine they are no longer needed, while retaining a minimal suppression record where necessary to respect your choice; and
- website analytics: according to the retention settings applied within the relevant service.
We may retain information for longer where required by law, an insurer or a dispute, or where there is another documented reason. When information is no longer needed, it is deleted, anonymised or securely destroyed.
08
Marketing
We use Zanda to send clinic news, service information and offers by email where you have consented or where the PECR soft opt-in lawfully applies to our own similar services. Every marketing email should provide a way to unsubscribe. You can also opt out at any time by emailing fitaj@hotmail.co.uk.
You have an absolute right to object to the use of your personal information for direct marketing. If you object or unsubscribe, we will stop sending that marketing. We may retain limited details on a suppression list so that we can respect your choice.
09
Cookies and analytics
Our website uses essential technologies needed for security and basic operation. With your permission, it may also use Google Analytics to help us understand website use and improve the visitor experience.
Cookiebot presents the cookie banner and records your choices. You can accept, reject or adjust non-essential cookies through the cookie controls. Withholding consent for non-essential cookies should not prevent you from using the main website.
10
Your rights
Depending on the circumstances and lawful basis, you may have the right to:
- ask for a copy of your personal information;
- ask us to correct inaccurate or incomplete information;
- ask us to delete information;
- ask us to restrict how information is used;
- object to certain uses, including direct marketing;
- receive certain information in a portable format;
- withdraw consent at any time where consent is the basis used; and
- complain to the Information Commissioner’s Office.
These rights are not absolute and exemptions may apply. We may need to confirm your identity before acting on a request. We normally respond within one month.
11
Contact and complaints
To ask a privacy question or exercise your rights, contact:
HUMAN UPGRADE LTD
Ash Cottage, St James Road
Sway, Lymington, Hampshire
SO41 6AN
fitaj@hotmail.co.uk
Please contact us first so we have an opportunity to resolve your concern. You also have the right to complain to the Information Commissioner’s Office, the UK data-protection regulator.
Changes to this policy
We may update this policy when our services, suppliers or legal obligations change. The version and dates at the top show when it was last updated and when it is scheduled for review.