On 25 May 2018, the most significant piece of European data protection legislation to be introduced in 20 years came into force. The EU General Data Protection Regulation (GDPR) replaced the 1995 EU Data Protection Directive. The GDPR strengthens the rights that individuals have regarding personal data relating to them and seeks to unify data protection laws across Europe, regardless of where that data is processed.
Energy4Life is committed to fulfilling all the requirements of the new legislation which has strict policies on how your data is managed.
The GDPR sets out the following data rights applicable to our customers and their clients:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (also known as the 'right to be forgotten')
- The right to restrict processing
- The right to data portability
- The right to object
SAR Form Download: E4L Health Subject Access Request Form
Energy4Life understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out below.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal
- The right to object to us using your personal data for a particular purpose or
- The right to data This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profilin (we do not use your personal data in this way)
For more information about our use of your personal data or exercising your rights as outlined above, please contact us
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
Email address |
Carrying out contract of sale |
Our legitimate interests in enabling our customers to access and use our services and ensuring the security of our website, network, systems and data |
Date registered with E4L |
Reporting on sales information |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Language |
Display of data in the correct language |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Name |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Gender |
Display of correct imagery in scan results |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
DOB |
Research data |
Our legitimate interests in developing products that better serve our customers |
Wellness Rating |
Research data |
Our legitimate interests in developing products that better serve our customers |
Associated miHealth Devices |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Associated E4L scanners |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Biography |
Practitioner locator |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Testimonials |
Research data |
Our legitimate interests in developing products that better serve our customers |
E4L Scan Data |
Carrying out contract of sale |
Our legitimate interests in enabling our customers to access and use our services and ensuring the security of our website, network, systems and data |
Shop Orders |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Delivery Address |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Billing Address |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Payment Information |
Carrying out contract of sale |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services |
Research Questionnaire Results |
Research data, machine learning and artificial intelligence |
Our legitimate interests in developing products that better serve our customers |
Intake Form Data |
Carrying out contract of sale, research data, machine learning and artificial intelligence |
The legitimate interests of us and our customers in entering into and performing contracts for providing and receiving requested services and interests in developing products that better serve our customers |
Voice Data |
Research data, machine learning and artificial intelligence |
Our legitimate interests in developing products that better serve our customers |
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your
- Supplying our products and services to Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring products and services
- Communicating with This may include responding to emails or calls from you.
- Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the link at the bottoms of marketing emails).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- All data regarding your transactions with us has to kept for 10 years
- All E4L scan and miHealth information has to be kept for 10 years
- Any other information will be kept for 5 years after your last login to the E4L Portal
How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in countries which comply with GDPR policies.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- All your data will be stored
- Any paper based version of your data will be shredded unless required by law to retain. Where required by law, your data will be held in a secure storage facility
- All electronic data is stored on servers which have strict security policies and adhere to GDPR
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We may share your personal data with other companies in our group for providing you with the service and products required by you. This includes subsidiaries.
We may sometimes contract with the following third parties to supply products and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. These parties include:
- Stripe - payment processing
- National Australia Bank - payment processing
- Royal Mail - package delivery
- DPD - package delivery
- UPS - package delivery
- TNT - package delivery
- Parcel Force - package delivery
- USPS - package delivery
- Australia Post - package delivery
- SAASU - accounts management
- Quickbooks - accounts management
- Pitney Bowes - package delivery
- HubSpot - customer management
- Infusionsoft - customer management
- MailChimp - customer communication
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: dataprotection@e4l.com
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.