Disclosure and Privacy Policy

Disclosure

The information presented in this website is intended for educational purposes only. It has not been evaluated by the Food and Drug Administration. This information is not intended to diagnose, treat, cure or prevent any condition or disease, nor is it medical advice. Always consult a qualified medical professional before engaging in dietary or lifestyle changes.

Privacy Policy

This privacy policy is for this website [https://www.gapshealing.com] and served by Daphna Baryosef dba GAPS Healing, hereby “the website”, “the owner” “GAPS Healing”, and governs the privacy of its users who choose to use it.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.

GAPS Healing holds some information about you. This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the admin@gapshealing.com.  We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2021.

What We Do at GAPS Healing

GAPS Healing provides educational resources to users of the website to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, the optimization of physical and mental health and chronic health conditions. 

We also offer paid consultations by a Certified GAPS Practitioner. Through consultations, dietary and lifestyle analysis, we aim to understand the underlying causes of your health issues which we will seek to address through personalized dietary recommendations and lifestyle advice.

How We Obtain Your Personal Data

Information provided by you:

You provide us with personal data in the following ways:

• By completing a nutritional therapy questionnaire
• By signing a terms of engagement form
• During a nutritional therapy consultation
• Through email, over the telephone or by post
• By taking credit card and online payment
• This may include the following information:
• Basic details such as name, address, contact details and next of kin
• Details of contact we have had with you such as referrals and appointment requests
• Health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans
• Primary care practitioner contact information
• Bank details

We use this information in order to provide you with direct healthcare.  This means that the legal basis of our holding your personal data is for legitimate interest.

Following completion of your healthcare we retain your personal data for the period defined by our professional association.  This enables us to process any complaint you may make.  In this case the legal basis of our holding your personal data is for contract administration.

Information we get from other sources

We may obtain sensitive medical information in the form of test results from biochemical testing companies.  We use this information in order to provide you with direct healthcare.  This means that the legal basis of our holding your personal data is for legitimate interest.

We may obtain sensitive information from other healthcare providers.  The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.

How we use your personal data

We act as a data controller for use of your personal data.  We also act as a controller and processor in regard to the processing of your data from third parties such as testing companies and other healthcare providers.  We act as a data controller and processor in regard to the processing of credit card and online payments.

We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) concerning data protection.  We will also take reasonable security measures to protect your personal data storage.

We may use your personal data where there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime.  Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters if you opt into an email form.

Confidentiality

We will keep information about you confidential.  We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

• Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential
• Anyone to whom we may transfer our rights and duties under any agreement we have with you
• Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so

We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare.  We will not include any sensitive information.

We will seek your express consent before sharing your information with other healthcare providers.  However if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or in case of self-harm) using the legal basis of vital interests.

We may share your case history in an anonymized form with our peers for the purpose of professional development.  This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites.  We will seek your explicit consent before processing your data in this way.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Your Rights

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.

If you want to access your data you must make a subject access request in writing to daphna@gapshealing.com.  Under special circumstances, some information may be withheld.   We shall respond within 20 working days from the point of receiving the request and all necessary information from you.  Our response will include the details of the personal data we hold on you including:

• Sources from which we acquired the information
• The purposes of processing the information
• Persons or entities with whom we are sharing the information

You have the right, subject to exemptions, to ask to:

• Have your information deleted
• Have your information corrected or updated where it is no longer accurate
• Ask us to stop processing information about you where we are not required to do so by law.
• Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
• Object at any time to the processing of personal data concerning you.

We do not carry out any automated processing, which may lead to automated decision based on your personal data. If you would like to invoke any of the above rights then please email admin@gapshealing.com.

Data Safeguards

We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

Website technical details

The Website

This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all USA national laws and requirements for user privacy.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Visitor comments may be checked through an automated spam detection service.

Use of Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information [http://www.google.com/privacy.html ].

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

Login Cookies

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

If you request a password reset, your IP address will be included in the reset email.

Contact & Communication

Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.

This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.

Email Newsletter

This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.

Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list].

This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

External Links

Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. External links are clickable text / banner / image links to other websites.

The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Advertisements and Sponsored Links

This website may contain sponsored links and advertisements. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.
Clicking on any such advertisements will send you to the advertisers website through a referral program which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computers hard drive. Users should therefore note they click on sponsored external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Shortened Links in Social Media

This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls (web addresses).

Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.