Privacy Notice

Healthy New Me • Version 2.0 • August 2026

1) About this Privacy Notice

This Privacy Notice explains how Healthy New Me (HNM) collects, uses, stores and retains personal information when you become a member, attend HNM, communicate with HNM or otherwise use HNM services.

HNM is committed to handling personal information fairly, securely and transparently and in accordance with applicable UK data protection law, including the UK GDPR and Data Protection Act 2018.

This notice should be read alongside the HNM Membership Agreement and any specific consent forms you are asked to complete, such as the Photography and Video Consent Form.

2) Who is responsible for your information?

Healthy New Me is a sole trader business operated by Liz Eate and is responsible for deciding how and why your personal information is processed for the purposes described in this notice.

For privacy questions or requests, contact:

Email: liz@healthynewme.net
Telephone: 07305 740 768
Website: www.healthynewme.net

If you have a concern about how your information has been handled, please contact HNM first so that the issue can be considered and addressed where possible. You also have the right to complain to the Information Commissioner's Office (ICO).

3)What information we collect

Depending on your relationship with HNM, we may collect:

Identity and contact information, such as your name, telephone number, email address and other contact details you choose to provide.
Membership information, including your membership type, visits, dates, payment status, expiry dates, holiday extensions, reconnection and relevant communications.
Wellness Evaluation and review information, which may include weight, height, body measurements, body composition information, blood pressure where taken, goals, progress information and other wellbeing measures.
Health and wellbeing information that you choose to provide so that HNM can provide appropriate coaching and support, such as relevant health conditions, allergies, dietary requirements, medication information or advice/restrictions from your healthcare professionals.
Information arising from communications with HNM, including questions, feedback, complaints and information relevant to your membership or safety.
Emergency contact information, where you choose to provide it, including the contact's name, relationship to you and contact details.
Information relating to safeguarding, accidents, injuries or incidents where HNM has a professional or legal responsibility to record or act on the information.
Photography and video where you have provided the relevant consent.

HNM aims to collect only information that is adequate, relevant and reasonably necessary for the purposes for which it is used. Health information is treated as special category data and receives additional protection under data protection law. ICO: special category data

4) Where we get information from

Most information is provided directly by you when you join HNM, complete a Wellness Evaluation or review, communicate with HNM, make a payment, use HNM services or complete a consent form.

HNM does not routinely obtain health or wellbeing information about you from healthcare professionals or other organisations. Information is normally provided directly by you.

5) Why we use your information

To set up and administer your HNM membership.
To arrange and record Wellness Evaluations and reviews.
To provide personalised coaching, wellbeing support and nutritional guidance.
To understand relevant health and wellbeing information so that coaching can be provided safely and appropriately.
To record visits, holiday extensions, payments, expiry dates, reconnection and other membership administration.
To communicate with you about your membership, HNM activities, changes, closures, safety and other relevant matters.
To respond to questions, feedback and complaints.
To manage accidents, incidents and safeguarding concerns and meet professional or legal responsibilities.
To keep appropriate records and comply with legal, regulatory and professional requirements.
To manage behaviour, maintain a safe HNM environment, record relevant incidents and make decisions about membership where necessary.
Where you have given appropriate consent, to use photography or video for progress recognition, community celebration and HNM marketing or promotional purposes.

6) Our lawful basis for using information

UK data protection law requires HNM to have a lawful basis for processing personal information. The basis used depends on what we are doing with the information. The ICO explains what privacy information should include.

Purpose

Membership administration and providing contracted services

Likely lawful basis

Contract – processing necessary to provide and administer the membership you have purchased.

Legal, regulatory and professional record-keeping

Legal obligation where applicable, and/or legitimate interests where appropriate.

Managing safety, incidents and safeguarding

Legal obligation, vital interests or legitimate interests where applicable to the circumstances.

Communications and community administration

Contract and/or legitimate interests, depending on the purpose.

Consent where consent is requested.

Photography/video and optional promotional use

An Article 6 lawful basis plus an applicable Article 9 condition for special category data. Explicit consent will be used where appropriate.

Health and wellbeing information

Health information is special category data. HNM will only process it where both an Article 6 lawful basis and an appropriate Article 9 condition under the UK GDPR apply. ICO: special category data

Where HNM relies on consent, consent must be freely given, specific, informed and unambiguous, involve a positive opt-in, and be capable of being withdrawn at any time. Where explicit consent is required for special category health information, HNM will obtain an express statement of consent. ICO: consent

7) Wellness and health information

HNM uses relevant health and wellbeing information to support coaching and to help ensure that advice and participation are appropriate. HNM is not a GP, hospital or other provider with access to your complete medical record.

You remain responsible for following advice from your own healthcare professionals. HNM may recommend that you seek medical or other professional advice where appropriate.

HNM will only collect and retain personal and health information that is adequate, relevant and reasonably necessary for the purposes for which it is used. HNM relies on the information provided by members and does not independently verify its accuracy or completeness. HNM cannot be responsible for risks or outcomes arising from relevant information that has not been disclosed. We will periodically review the information we hold and delete information that is no longer needed, subject to our legal, regulatory, professional and other retention requirements. ICO: data minimisation

8) Photography and video

HNM may take photographs or video during Wellness Evaluations, reviews and HNM activities. These may include progress photographs, goal/celebration board photographs and general photographs of members enjoying HNM.

Where an image is to be used beyond the immediate service provided to you, HNM will use the Photography and Video Consent Form to record your choices. The consent form separates private HNM member-community use from public or promotional use, including website and social media. Consent is reviewed at member reviews, normally at least once during each membership period.

You can change or withdraw consent for future use. Withdrawal does not make previous lawful processing unlawful, and HNM may not be able to retrieve material that has already been printed, published or shared before withdrawal.

9) Communications and the private members' group

HNM's preferred communication channels are WhatsApp, text/SMS, Facebook Messenger, the private HNM members' group and email. HNM may have a presence on other social media platforms, but members should use the preferred channels for membership, health, safety or other personal matters.

The private group is a community space. Members should not post personal, sensitive or confidential information about themselves or other people there. The group should not be used for urgent medical or safeguarding concerns.

Third-party platforms such as WhatsApp, Facebook/Messenger and other communication services have their own privacy policies and terms. Information shared through those services may also be processed by those providers. Members should consider the information they choose to share through them.

10) Who may receive your information?

HNM does not sell members' personal information.

Information may be shared where necessary and lawful with:

Service providers who help HNM operate its business, such as payment, communication, website, IT or secure storage providers.
Professional advisers or insurers where reasonably necessary.
Healthcare, emergency or safeguarding services where this is necessary and lawful, including where HNM has a professional or legal duty to act.
Law enforcement, regulators or other authorities where HNM is legally required or permitted to disclose information.

Where members purchase Herbalife products through HNM, personal information may be shared with Herbalife or its relevant systems where necessary to process and fulfil the order. This may include name, contact and delivery details, order information and payment information. HNM does not share members' health, Wellness Evaluation, coaching or other sensitive wellbeing information with Herbalife. Herbalife's UK Privacy Policy and Distributor Privacy Policy

HNM will only share information that is relevant to the purpose and permitted by applicable law.

11) Keeping your information secure

HNM takes reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

HNM stores information in paper and electronic formats. Paper records may be held securely at HNM or at HNM's administrative premises. Electronic information may be stored on password-protected devices and digital systems used to operate HNM. Relevant information may also exist within communication platforms such as WhatsApp, Facebook/Messenger and text messages.

No method of storing or transmitting information is completely risk-free. Where HNM uses third-party systems, those providers may have their own security arrangements and privacy responsibilities.

12) How long we keep your information

HNM does not keep personal information indefinitely. Information is retained only for as long as it is reasonably necessary for the purpose for which it was collected, and to meet legal, regulatory, professional, insurance, accounting or other legitimate record-keeping requirements.

Membership and payment records will generally be retained for the period necessary to administer the membership and meet applicable legal and accounting requirements.
Wellness, health and review information will be retained for as long as reasonably necessary for the coaching relationship and any applicable legal, regulatory or professional requirements.
Consent records will be retained for as long as necessary to demonstrate and manage the choices you have made.
Photography and video will be retained only for as long as reasonably necessary for the purpose for which it was collected, subject to your consent and any need to maintain records of previous use.
Complaint, accident and safeguarding records may need to be retained for longer where required by law, professional obligations, insurance or safeguarding requirements.

HNM will review its retention arrangements and adapt them where legal or regulatory requirements change.

13) What happens when you leave HNM?

When your membership ends, your unused visits expire in accordance with the Membership Agreement.

Your personal information is not automatically deleted on the day your membership ends.

HNM will retain information for the periods reasonably required for legal, regulatory, professional, insurance, accounting, safeguarding and legitimate business purposes. When information is no longer required, HNM will securely delete it or anonymise it where appropriate.

14) Your rights

Subject to legal exceptions and the circumstances of the processing, you may have rights under UK data protection law to:

Ask for a copy of the personal information HNM holds about you.
Ask HNM to correct inaccurate or incomplete information.
Ask for your information to be erased in certain circumstances.
Ask HNM to restrict processing in certain circumstances.
Object to certain processing, including some processing based on legitimate interests.
Ask for your information to be provided to you or another organisation in a structured, commonly used and machine-readable format where the right to data portability applies.
Withdraw consent where HNM is relying on consent for the processing.

Some rights are not absolute and may not apply to every type of information. For example, HNM may need to retain information where there is a legal or professional requirement to do so.

Formal requests relating to your personal information or data protection rights must be made in writing by email to liz@healthynewme.net. This helps HNM verify and manage requests securely and consistently.

15) Complaints about your information

If you have concerns about how HNM has collected, used or stored your information, please contact HNM first. HNM will consider your concern and seek to resolve it where possible.

You can also complain directly to the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection.

16) Changes to this Privacy Notice

HNM may update this Privacy Notice from time to time to reflect changes in its services, information-handling practices, technology or legal and regulatory requirements. The current version will be published on the HNM website.

Where a change is significant, HNM will take reasonable steps to bring it to members' attention.

17) Contact HNM

For questions about this Privacy Notice, your personal information or your data protection rights:

Email: liz@healthynewme.net
Telephone: 07305 740 768
Website: www.healthynewme.net