CHE PRO Privacy Policy
Version 1.0 · Effective from 1 September 2026
1. About this policy
- This policy explains how we collect and use personal information about CHE PRO Members, people who are thinking of joining (including people who complete our scorecard), and visitors to CHE PRO websites and community spaces. It also explains how we use cookies and what rights you have.
- We comply with UK data protection law (the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations) and, where it applies to you, the EU General Data Protection Regulation.
- Words with capital letters, such as “Member”, “Community” and “Live Session”, have the meanings given in our CHE PRO Membership Terms and Conditions.
2. Who we are
- CHE Health & Wellbeing Limited (“CHE”, “we”, “us” and “our”) is the controller of your personal information. We are registered in England and Wales under company number 10722903, our registered office is 4th Floor, 100 Fenchurch Street, London EC3M 5JD, and we are registered with the Information Commissioner’s Office under registration number ZB035578.
- We are part of the Centre for Homeopathic Education group, which also includes CHE Group Ltd, CHE Online Limited, CHE (UK) Limited and CHE International Ltd.
- Data Protection Officer. You can contact our Data Protection Officer by emailing [email protected], marked “For the attention of the Data Protection Officer”, or by post to our registered office.
- Representative. We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following region: the European Union (EU). Prighter gives you an easy way to exercise your privacy-related rights (for example, requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data subject rights, please visit https://app.prighter.com/portal/EU-GDPR.
3. The information we collect
3.1 Depending on how you interact with us, we collect the following types of personal information:
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Type of information
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Examples
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|---|---|
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Identity and contact
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Name, email address, phone and mobile number (including WhatsApp), country, profile photo
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Professional details
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Training provider, qualifications and certificates you upload, years in practice, whether you currently see patients and professional body membership
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Scorecard responses
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Your answers to The Practising Homeopath Scorecard and the scores and results generated from them
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Account and learning
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Login details, course progress, videos completed, CPD Certificates issued, sessions attended, time zone
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Payments
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Plan, payment dates and amounts, refunds, billing address and partial card details (your full card details are held by our payment providers, not by us)
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Community and Live Sessions
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Posts, comments, messages, reactions and profile information; your name, image, voice, chat messages and questions in recorded Live Sessions
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Casework
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Cases you present or discuss, which must be anonymised or shared with the patient's explicit consent (see section 6)
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Communications
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Emails, support requests, complaints, survey responses, and any consent you give for testimonials or marketing clips
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Marketing
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Your marketing preferences and how you interact with our emails, SMS and WhatsApp messages
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Technical
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IP address, device and browser type, pages viewed, referring website and cookie identifiers
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3.2 We do not ask for information about your own health, religion, ethnicity or other special categories of personal information. Please avoid sharing it in the Community unless it is necessary.
4. Where we get it from
- Directly from you, when you complete the scorecard, join, verify your eligibility, use the Platform, attend Live Sessions, post in the Community or contact us.
- From our payment providers (Kajabi Payments, Thinkific Payments, Stripe and PayPal) when you pay.
- Automatically, through the Platform, cookies and similar technologies.
- From other companies in the CHE group, for example if you studied with CHE.
5. How we use it and our lawful bases
5.1 We use your personal information for the purposes below, relying on the lawful basis shown for each:
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Purpose
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Lawful basis
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|---|---|
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Setting up and providing your Membership, including the Library, Live Sessions, Community and CPD Certificates
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Contract
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Checking your eligibility and qualifications
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Contract; legitimate interests in keeping CHE PRO a professional community
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Taking payments, renewals and refunds, and handling failed payments
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Contract
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Sending service messages, such as payment confirmations, renewal reminders and changes to our Terms
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Contract; legal obligation
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Recording Live Sessions and Casework Workshops and adding them to the Library
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Legitimate interests in giving all Members, in every time zone, access to every session
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Moderating the Community and enforcing our Terms and Code of Conduct
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Legitimate interests in a safe, professional community
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Using written Community contributions for teaching and FAQs
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Contract (Terms clause 12.4); legitimate interests
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Using clips of you in marketing, testimonials or case studies
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Consent, which you give specifically and can withdraw at any time
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Scoring your scorecard and sending your results
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Consent
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Sending marketing by email, SMS and WhatsApp about CHE PRO and other CHE education
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Consent; or, for existing Members, legitimate interests in telling you about similar services, with an easy way to opt out in every message
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Sharing information with CHE group companies for administration and to tell you about CHE education
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Legitimate interests; consent where the law requires it for marketing
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Website analytics to understand how CHE PRO is used and improve it
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Legitimate interests (see section 11)
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Advertising, including measuring adverts and building audiences on Meta and Google
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Consent
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Business reporting and analysis, including AI-assisted analysis
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Legitimate interests in running and improving our business
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Accounting, tax, and keeping CPD records for audit by accreditation bodies
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Legal obligation; legitimate interests
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Handling complaints, disputes and legal claims
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Legitimate interests; legal obligation
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5.2 Where we rely on legitimate interests, we have balanced our interests against your rights and freedoms. You can object at any time (section 10).
5.3 Automated scoring. Your scorecard answers are scored automatically to produce a score tier and to tailor the information we send you. This does not have any legal or similarly significant effect on you. Decisions about eligibility for Membership are made by a person.
5.4 AI tools. We use AI tools, including services provided by Anthropic, to support business analysis and operations, such as reporting on total member numbers and cancellations. We use aggregated figures for analysis wherever possible, and we do not permit our AI providers to use your personal information to train their models.
6. Casework and patient information
When a Member presents a case, that Member is the controller of their patient’s information and is responsible for anonymising it or obtaining the patient’s explicit consent before sharing it, as required by clause 11 of our Terms.
A fully anonymised case is not personal information. Where identifiable health information is shared with the patient’s explicit consent, we process it, including in recordings added to the Library, on the basis of that explicit consent (UK GDPR Article 9(2)(a)) and our legitimate interests in providing professional education (Article 6(1)(f)).
A Member can ask for their case not to be included in the Library. If you are a patient and believe your information has been shared through CHE PRO, please contact your practitioner or email [email protected]. We will investigate and remove or edit the material where appropriate.
7. Who we share it with
7.1. We do not sell your personal information. We share it only with the recipients below, and only as far as necessary.
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Recipient
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Purpose
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|---|---|
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Setting up and providing your Membership, including the Library, Live Sessions, Community and CPD Certificates |
Group administration and finance, and telling you about CHE education
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Thinkific, Kajabi and Circle
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Hosting the Platform, Library, Community and member accounts
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Zoom
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Delivering Live Sessions
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Kajabi Payments, Thinkific Payments, Stripe and PayPal
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Processing payments and refunds
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ActiveCampaign
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Email and SMS communications and customer records
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ScoreApp
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Running the scorecard
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Meta (including WhatsApp)
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WhatsApp messaging and, with your consent, advertising
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Business email and documents, website analytics and, with your consent, advertising
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Xero
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Accounting and invoicing
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Anthropic
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AI-assisted business analysis and operations
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Professional advisers (such as accountants, lawyers and insurers)
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Professional advice and protecting our business
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Accreditation and professional bodies
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Confirming CPD where you ask us to, or for accreditation audits
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7.2 Other Members, teachers and moderators can see your name, profile, posts and contributions in the Community and in Live Sessions, and in recordings in the Library.
7.3 We may also disclose information where the law requires it, to protect the rights and safety of CHE, Members or others, or to a buyer or successor if the CHE PRO business or a CHE group company is sold or restructured.
7.4 Our service providers act on our instructions under contracts that require them to protect your information. Some, such as payment providers, Meta and Google, also use information as independent controllers for their own purposes (for example fraud prevention), under their own privacy policies.
8. International transfers
- CHE staff access member information from the UK only. Several of our service providers are based in, or process information in, the USA and Canada, and may also use other countries.
- When personal information is transferred outside the UK, we make sure it is protected by UK adequacy regulations (for example for the European Economic Area and Canada), by the UK Extension to the EU-US Data Privacy Framework where the US recipient is certified, or by the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.
- For Members in the European Union, the European Commission recognises the UK as providing adequate protection for personal information, and onward transfers are protected by equivalent safeguards. Contact us for a copy of the safeguards we rely on.
9. How long we keep it
9.1 We keep personal information only for as long as we need it, as follows:
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Information
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How long we keep it
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|---|---|
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Account, profile, eligibility documents and support records
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For your Membership and 2 years after it ends
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CPD Certificate records
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6 years from the date of issue
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Payment and financial records
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6 years from the end of the financial year they relate to
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Recordings of Live Sessions and Casework Workshops
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For as long as the recording remains in the Library
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Community contributions used for teaching and FAQs
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For as long as they remain in use
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Scorecard responses from people who do not join
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2 years from your last interaction with us
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Marketing opt-outs
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Indefinitely, so that we do not contact you again
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10. Your rights
10.1 You have the right to:
- Access the personal information we hold about you;
- Have inaccurate information corrected;
- Have your information erased;
- Restrict how we use your information;
- Object to our use of your information, including an absolute right to object to direct marketing;
- Receive your information in a portable format;
- Withdraw consent at any time, without affecting anything we did before you withdrew it; and
- Not be subject to decisions based solely on automated processing that have legal or similarly significant effects on you.
10.2 To exercise any right, email [email protected]. We will respond within one month, which we may extend by up to two further months for complex requests. We may need to confirm your identity, and we will carry out reasonable and proportionate searches to respond to access requests.
10.3 Trust Center. We also provide an easy way to submit privacy requests, such as a request to access or erase your personal data, through our Trust Center: https://app.prighter.com/portal/EU-GDPR.
10.4 Some rights are subject to exceptions. For example, we must keep financial records for the period the law requires.
11. Cookies and similar technologies
11.1 Cookies are small files placed on your device. We and our Platform providers use the following:
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Type
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What it does
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Your choice
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|---|---|---|
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Strictly necessary
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Log-in, checkout, security and remembering your cookie choices
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Always on, as the Platform cannot work without them
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Analytics (Google Analytics)
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Produces statistics on how CHE PRO is used so we can improve it
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You can accept or decline these through our Cookie Consent Popup
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Advertising (Meta Pixel and Google advertising tags)
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Measures our adverts and shows CHE adverts to you and similar audiences on other websites
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Only set if you accept them in our Cookie Consent Popup
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11.2 When you first visit CHE PRO, our Cookie Consent Popup asks you to accept or decline non-essential cookies. You can change your choices at any time through the Cookie Consent Popup, or by clearing cookies for our website in your browser settings, which will display the popup again. Blocking strictly necessary cookies may stop the Platform from working.
11.3 Thinkific, Kajabi, Circle, Zoom and our payment providers also set cookies on their own platforms under their own cookie policies.
12. Marketing
12.1 We send marketing by email, SMS and WhatsApp. We will only do so where you have agreed, or where the law allows us to contact existing Members about similar services.
12.2 You can opt out at any time by using the unsubscribe link in any email, replying STOP to an SMS or WhatsApp message, or emailing [email protected]. Opting out of marketing does not stop service messages, such as payment confirmations and renewal reminders.
13. Security
13.1 We use appropriate technical and organisational measures to protect your information, including access controls, restricting staff access to those who need it and requiring our providers to keep information secure. No system is completely secure, so please keep your login details safe and tell us immediately if you think your account has been compromised.
14. Children
14.1 CHE PRO is only for people aged 18 and over, and we do not knowingly collect personal information from children, other than in casework shared in line with section 6.
15. Complaints
15.1 If you have a concern about how we use your personal information, please contact us first at [email protected]. We will acknowledge your complaint within 30 days and respond without undue delay.
15.2 You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or by phone on 0303 123 1113. If you live in the European Union, you can complain to the data protection authority in your country.
16. Changes to this policy
16.1 We may update this policy from time to time. We will tell Members about significant changes by email or on the Platform, and the version date at the top shows when it was last updated.