Effective Date: May 12, 2025

1. Introduction

Welcome to Momentum Clinic (“we,” “us,” or “our”). We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.momentumclinic.com (the “Site”), and when you use our services, including interactions facilitated through third-party applications like Jane App and Heidi Health App.  

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site or use our services.  

We operate in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Who We Are

Momentum Clinic, located at 122 Torquay Road, Newton Abbot TQ124AH, is the controller responsible for the personal data collected directly via our Site (e.g., through contact forms or website analytics). For data processed within Jane App and Heidi Health App for booking, clinical records, and other related services, we act as a controller, but the processing is also subject to the privacy policies of those respective platforms.

3. Information We Collect

We may collect personal information about you in various ways:

• Information You Provide Directly:
  • Contact Information: Name, email address, phone number when you fill out contact forms or subscribe to newsletters.
  • Health Information: You may provide preliminary health details via contact forms, but sensitive health information required for assessment and treatment is primarily collected through secure platforms like Jane App and Heidi Health App during registration, booking, or consultations.
  • Communication Records: Records of your correspondence with us via email or the Site.
• Information Collected Automatically:
  • Log and Usage Data: IP address, browser type, operating system, referring URLs, pages viewed, time spent on pages, device information, and dates/times of access when you visit our Site. This is often collected via cookies and similar technologies.
• Information Collected via Third-Party Applications (Jane App & Heidi Health App):

• When you book appointments, manage your account, fill out intake forms, or interact with clinical features, you will be using Jane App and/or Heidi Health App. These platforms collect significant personal and sensitive health information directly from you, including but not limited to:
  • Demographic information (name, date of birth, address, contact details)
  • Appointment history
  • Clinical notes and medical history
  • Billing and insurance information
  • Communication logs within the apps
• Momentum Clinic accesses and uses the information stored within Jane App and Heidi Health App to provide you with clinical services, manage your appointments, and handle billing. The collection and processing of data within these apps are governed by their respective privacy policies.

4. How We Use Your Information

We use the information we collect for various purposes, including:

• Providing and Managing Services: To schedule appointments, provide clinical assessments and treatments, manage your patient records (primarily via Jane App/Heidi Health App), and process payments.  
• Communication: To respond to your inquiries, send appointment reminders (often via Jane App/Heidi Health App functionality), provide information about our services, and send important updates.
• Website Operation and Improvement: To monitor and analyse website usage and trends, maintain website security, and improve user experience.
• Legal and Regulatory Compliance: To comply with applicable laws, regulations, legal processes (e.g., subpoenas), and professional record-keeping obligations.
• Marketing (with Consent): To send you newsletters or promotional materials, but only where we have your explicit consent to do so.

5. Legal Basis for Processing (UK GDPR)

We process your personal data based on the following legal grounds:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., subscribing to a newsletter, non-essential cookies). You can withdraw consent at any time.  
• Contract: Where processing is necessary for the performance of a contract with you (e.g., providing the clinical services you have booked).
• Legal Obligation: Where processing is necessary for us to comply with the law (e.g., maintaining patient health records as required by healthcare regulations).
• Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided your rights and interests do not override those interests (e.g., website security, analytics for service improvement).  
• Processing Special Category Data (Health Information): We process your sensitive health data based on:
• Your explicit consent; and/or
• Necessity for the purposes of preventative or occupational medicine, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services.  

6. Data Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:  

• Third-Party Service Providers:
  • Jane App & Heidi Health App: As integral parts of our service delivery for booking, patient records management, communication, and potentially telehealth, your data is processed by these platforms. We encourage you to review their privacy policies:
    • Jane App Privacy Policy: https://jane.app/legal/privacy-policy
    • Heidi Health App Privacy Policy: https://www.heidihealth.com/uk/legal/privacy-policy
  • Other Providers: We may share information with other vendors who perform services for us, such as IT support, website hosting, analytics providers, or payment processors. These providers are obligated to protect your data.
• Legal Requirements: We may disclose your information if required by law, regulation, court order, or other governmental authority, or to protect our rights or the safety of others.  
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.  

7. Data Security

We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. This includes measures taken on our Site and relying on the security measures implemented by Jane App and Heidi Health App for data stored within those platforms. However, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of your data.  

8. Data Retention

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements (e.g., clinical record retention periods mandated by healthcare regulations). Website usage data collected for analytics may be kept for a shorter period.  

9. Your Data Protection Rights (UK GDPR)

Under UK data protection law, you have rights including:

• Right to Access: You have the right to request copies of your personal data.
• Right to Rectification: You have the right to request correction of any inaccurate information or completion of incomplete information.  
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• Right to Erasure (‘Right to be Forgotten’): You have the right to request the erasure of your personal data, under certain conditions.  
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• Right to Restrict Processing: You have the right to request the restriction of processing your personal data, under certain conditions.  
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• Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions (e.g., for direct marketing).  
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• Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
• Right to Withdraw Consent: Where we rely on consent as the legal basis, you have the right to withdraw that consent at any time.  

To exercise any of these rights, please contact us using the details below. We may need to verify your identity before processing your request.  

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).  

10. Cookies and Tracking Technologies

Our Site may use cookies and similar tracking technologies (like web beacons and pixels) to collect and store information about your Browse activities. This helps us operate the Site, analyse usage, and improve your experience. You can manage your cookie preferences through your browser settings. Please refer to our separate Cookie Policy [Link to Cookie Policy – *You should create one*] for more detailed information.

11. Children’s Privacy

Our Site and services are not intended for individuals under the age of 16 without verifiable parental consent. We do not knowingly collect personal information from children under this age without such consent. If we become aware that we have inadvertently collected such information, we will take steps to delete it.

12. International Data Transfers

Your information may be transferred to, stored, and processed in countries outside of the UK or the European Economic Area (EEA), particularly by third-party service providers like Jane App or Heidi Health App if their servers are located elsewhere. Where this occurs, we ensure appropriate safeguards are in place to protect your data, such as adequacy decisions or Standard Contractual Clauses approved by the relevant UK authorities.

13. Links to Other Websites

Our Site may contain links to other websites not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.  

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top. We encourage you to review this Privacy Policy periodically for any changes.  

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Momentum Clinic  

122 Torquay Road, Newton Abbot TQ124AH

[email protected] 

01626337053