Centre for Homeopathic Education (CHE) group: websites, courses, app and services
Controller: CHE Health & Wellbeing Limited, company number 10722903, ICO registration ZB035578
Data protection enquiries and requests: [email protected] (Data Protection Lead)
All other enquiries: [email protected] · 020 3405 4580
1.1 This policy explains how we collect and use personal information about people who visit our websites, enquire about or apply for our courses, study with us, apply for a scholarship, use the CHE app, attend our events, receive our communications or apply to work with us. It also explains how we use cookies and what rights you have.
1.2 It covers chehomeopathy.com, cheonline.co.uk, the CHE mobile app, our learning platforms and community spaces, and our events and communications.
1.3 Two groups of people have their own notice, which applies instead of this policy where the two differ:
1.4 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.
2.1 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 trade as the Centre for Homeopathic Education (CHE).
2.2 CHE Health & Wellbeing Limited is the group company of the CHE group, which also includes CHE Online Limited, CHE London Limited and CHE PRO Limited. Where you contract with another group company (for example for an online course), that company also uses your information for that contract, under the same rules and safeguards set out in this policy. CHE Health & Wellbeing Limited remains your point of contact for all data protection matters.
2.3 Data Protection Lead. Our Data Protection Lead, Marcus Fernandez, oversees how we handle personal information. Contact them at [email protected] or by post to our registered office, marked “For the attention of the Data Protection Lead”.
2.4 EU representative. We have appointed Prighter Group, with its local partners, as our representative in the European Union under Article 27 of the EU GDPR. If you are in the EU, you can contact us through Prighter, or use it to exercise your rights, at https://app.prighter.com/portal/EU-GDPR.
3.1 Depending on how you interact with us, we collect the following:
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Type of information
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Examples
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|---|---|
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Identity and contact |
Name, email address, phone and mobile number, postal address, country, date of birth, profile photo |
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Enquiries and applications |
Course of interest, application form, personal statement, qualifications and certificates, interview notes, our assessment of your English level, offer and acceptance records |
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Scholarship applications |
Application details and personal statement for the Dr Robin Murphy CHE Scholarship, and the decision |
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Student records |
Enrolment, course and module details, attendance and participation records (including Zoom and platform records and replay viewing), assignments, assessment results and feedback, deferral requests, awards and certificates |
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Support needs and extenuating circumstances |
Information you choose to give us about a disability, health condition or personal circumstances so that we can make reasonable adjustments or decide a deferral or extenuating circumstances request (see section 4) |
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Payments |
Course, fees and payment plan, payment dates and amounts, refunds, arrears, billing address and partial card details (your full card details are held by our payment providers, not by us) |
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Classes and community |
Your name, image, voice, chat messages and questions in recorded live classes; posts, comments and messages in our online community spaces |
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App and account |
Login details, course progress, device identifiers, operating system, push notification tokens, screens viewed, crash reports and approximate location (country or region from your IP address) |
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Communications |
Emails, calls, support requests, complaints, survey responses, and any consent you give for testimonials or case studies |
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Marketing |
Your marketing preferences, the source and date of your consent, and how you interact with our emails, SMS and WhatsApp messages |
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Technical |
IP address, device and browser type, pages viewed, referring website and cookie identifiers |
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Job and tutor applications |
CV, covering letter, right-to-work documents, references and interview notes |
3.2 We do not collect equality monitoring information, and we do not carry out criminal record checks on students.
4.1 Some information is given extra protection by law, such as information about your health. We only use it where you choose to give it to us, and only for the purpose you gave it for:
4.2 We rely on your explicit consent (UK GDPR Article 9(2)(a)) and, for reasonable adjustments, on our obligations under equality law (Data Protection Act 2018, Schedule 1). We have an Appropriate Policy Document that explains how we protect this information.
4.3 Only the staff who need to see this information can access it. We delete supporting evidence once the decision has been made and keep only a note of the outcome, such as the adjustment agreed or the new assessment date.
4.4 Students taking part in the CHE Homeopathy Clinic see patients’ health information. They must follow the confidentiality agreement they sign and our clinic rules. Patients’ information is covered by our Clinic Privacy Notice.
6.1 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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Answering enquiries and sending information you have asked for |
Legitimate interests in responding to you; steps you ask for before entering into a contract |
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Assessing applications, including interviews, and making offers |
Steps before entering into a contract; legitimate interests in admitting students who can succeed on the course |
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Assessing scholarship applications |
Legitimate interests in awarding scholarships fairly |
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Enrolling you and delivering your course, including teaching, assessment, attendance, progression and awards |
Contract |
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Taking fees, payment plans and refunds, and chasing unpaid fees |
Contract; legitimate interests in recovering money owed to us |
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Recording live classes and making recordings available to students on the course |
Legitimate interests in giving every student, in every time zone, access to every class |
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Providing reasonable adjustments and deciding deferral and extenuating circumstances requests |
Contract; legal obligation; explicit consent for health information (section 4) |
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Running the CHE app and your learning account, and keeping them secure |
Contract; legitimate interests in keeping our services secure |
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Sending service messages, such as timetables, assessment deadlines, payment reminders and changes to our terms
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Contract; legal obligation
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Moderating our community spaces and applying our Student Agreement and policies
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Contract; legitimate interests in a safe, respectful learning community
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Using your image, voice or story in testimonials, case studies or marketing
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Consent, which you can withdraw at any time
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Sending marketing about CHE courses and events by email or SMS
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Consent; or, for current and past students and customers, legitimate interests in telling you about similar CHE courses, with an easy way to opt out in every message
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Sending marketing by WhatsApp
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Consent
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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 and app analytics to improve our services
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Consent (analytics cookies, section 13); legitimate interests for app crash and performance reports
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Advertising, including measuring adverts and building audiences on Meta and Google |
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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Recruiting staff, tutors and supervisors
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Steps before entering into a contract; legal obligation (right-to-work checks)
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Accounting and tax, keeping student and award records for accreditation, and meeting other legal duties
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Legal obligation; legitimate interests
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Handling complaints, disputes and legal claims, and dealing with our insurers
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Legitimate interests; legal obligation
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Protecting someone's life in an emergency
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Vital interests
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6.2 Where we rely on legitimate interests, we have carried out a balancing test (a legitimate interests assessment) to check that our interests are not overridden by your rights and freedoms. You can ask us for details, and you can object at any time (section 11).
6.3 Automated decisions. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you. Admissions, scholarship, assessment, progression and deferral decisions are always made by people.
6.4 AI tools. We use AI tools, including services provided by Anthropic, to support business analysis and operations such as financial reporting. We send only aggregated figures to these tools, not information that identifies individual students or customers, and we do not allow our AI providers to use your information to train their models.
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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CHE group companies (CHE Online Limited, CHE London Limited and CHE PRO Limited)
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Group administration and finance, delivering courses and services, and telling you about CHE education
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Thinkific, Kajabi and Circle
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Hosting courses, learning accounts, the course library and online community spaces
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Zoom
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Delivering and recording live classes, interviews and meetings
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Stripe, PayPal, Thinkific Payments and Kajabi Payments
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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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Google (Google Workspace, Google Analytics, Google Ads)
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Business email and documents, website analytics and, with your consent, advertising
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Meta (including WhatsApp)
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WhatsApp messaging and, with your consent, advertising |
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Kinsta and our web and IT contractor
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Hosting and maintaining our websites (hosted in London)
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Amazon Web Services
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Hosting the CHE app and our internal systems (hosted in London)
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Complianz
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Recording your cookie choices
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Xero, our payroll provider and our accountants
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Accounting, invoicing, payroll and tax
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Anthropic
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AI-assisted business analysis using aggregated figures only
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CHE tutors, supervisors and staff
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Teaching, marking, supervision and student support, on a need-to-know basis and under confidentiality terms
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The Society of Homeopaths and other accreditation or professional bodies
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Confirming your studies or award where you ask us to, handling complaints referred to them, and accreditation audits
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Professional advisers (such as lawyers, accountants and insurers)
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Professional advice and protecting our business
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7.2 Other students on your course, tutors and moderators can see your name, profile, posts and contributions in live classes and community spaces, and in class recordings.
7.3 We may also disclose information where the law requires it, to protect the rights and safety of CHE, our students or others, or to a buyer or successor if a CHE group company or its business 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.
8.1 Our websites and the CHE app are hosted in the UK. Several of our service providers are based in, or process information in, the USA and Canada, and may also use other countries.
8.2 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.
8.3 For people 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 [email protected] for a copy of the safeguards we rely on.
9.1 We keep personal information only for as long as we need it, in line with our Data Retention and Erasure Policy:
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Information
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How long we keep it
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|---|---|
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CHE group companies (CHE Online Limited, CHE London Limited and CHE PRO Limited) |
24 months after your last contact with us
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Unsuccessful course and scholarship applications
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24 months after the decision |
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Student files (application, attendance, assessments, correspondence)Zoom
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5 years after you finish or leave your course
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Award record (your name, course, award and date)
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Permanently, so that we can confirm your qualification
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Evidence for reasonable adjustments, deferrals and extenuating circumstances
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Deleted once the decision has been made; we keep a note of the outcome in your student file
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Recordings of live classes
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For as long as the recording is used as course content
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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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Complaints, disputes and insurance files
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6 years after the matter is closed
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General email correspondence
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6 years
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Marketing contacts
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3 years after your last engagement with us
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Marketing opt-outs
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Permanently, so that we do not contact you again
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App usage logs and device data
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12 months
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Website analytics (Google Analytics)
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14 months
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Unsuccessful job and tutor applications
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6 months after the decision (right-to-work copies for people we engage: 2 years after they leave)
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9.2 We may keep information for longer where the law requires it or where we need it for a legal claim. When we no longer need information, we securely delete or anonymise it.
10.1 We use appropriate technical and organisational measures to protect your information, including:
10.2 If a personal data breach is likely to put your rights and freedoms at risk, we will report it to the ICO within 72 hours of becoming aware of it. If it is likely to put you at high risk, we will also tell you without undue delay.
10.3 No system is completely secure. Please keep your login details safe and tell us immediately at [email protected] if you think your account has been compromised.
11.1 You have the right to:
11.2 How to make a request. Email [email protected], write to the Data Protection Lead at our registered office, or, if you are in the EU, use our Prighter portal (section 2.4). You do not need to use a form, and there is normally no fee.
11.3 We will respond within one month. We may extend this by up to two further months for complex or multiple requests, and we will tell you if we do. We may need to confirm your identity, and we will carry out reasonable and proportionate searches to respond to access requests.
11.4 Deleting your account. You can delete your CHE app account in the app under Settings > Account > Delete My Account, or email [email protected] with the subject line “Data Deletion Request”. We will confirm when this is done.
11.5 Some rights are subject to exceptions. For example, we must keep financial records for the period the law requires, and we keep a permanent record of awards. We will tell you if an exception applies.
12.1 We send marketing by email, SMS and WhatsApp. We send it by email or SMS only where you have agreed, or where you are a current or past student or customer and the message is about similar CHE courses. We send marketing by WhatsApp only where you have agreed.
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 about your course, account or payments.
13.1 Cookies are small files placed on your device. We use the following on our websites:
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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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CHE group companies (CHE Online Limited, CHE London Limited and CHE PRO Limited) |
Security, forms, checkout and remembering your cookie choices
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Always on, as the website cannot work without them
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Analytics (Google Analytics)
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Produces statistics on how our websites are used so that we can improve them
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Only set if you consent
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Marketing (for example 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 consent
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13.2 Our cookie banner lists every cookie we use, with its provider, purpose and duration. You can change your choices at any time using the “Cookie settings” link in the website footer, and through your browser settings. Blocking strictly necessary cookies may stop parts of the website from working.
13.3 Thinkific, Kajabi, Circle, Zoom and our payment providers also set cookies on their own platforms under their own cookie policies.
14.1 Our courses, app and services are only for people aged 18 and over, and the CHE Homeopathy Clinic sees adults only. We do not knowingly collect personal information from children. If we find that we have done so, we will delete it promptly.
15.1 Our websites and app contain links to other websites. We are not responsible for their privacy practices, so please read their privacy policies.
16.1 If you have a concern about how we use your personal information, please contact our Data Protection Lead first at [email protected]. We will acknowledge your complaint within 30 days and respond without undue delay.
16.2 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.
17.1 We review this policy at least once a year. We will tell current students about significant changes by email or on our learning platforms, and the version and effective date at the top show when it was last updated.
All other enquiries: [email protected] · 020 3405 4580
Post: CHE Health & Wellbeing Limited, 4th Floor, 100 Fenchurch Street, London EC3M 5JD
EU representative: Prighter Group, https://app.prighter.com/portal/EU-GDPR
ICO registration: ZB035578
