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Privacy Policy

This privacy policy was updated on 15th September 2026.

 

This privacy policy applies between you, the User of this Website, and Eden New Life TNBI Ltd ('Eden New Life'), the owner and provider of this Website. Eden New Life takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

 

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.edennew.life/terms. Please read this privacy policy carefully.

 

Definitions and interpretation

  1. In this privacy policy, the following definitions are used:

     

  • Data: collectively all information that you submit to Eden New Life via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

     

  • Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

     

  • Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act 2025, and any national implementing and supplementary laws, regulations and secondary legislation;

     

  • GDPR: the UK General Data Protection Regulation, the Data Protection Act 2018, and the Data (Use and Access) Act 2025;

     

  • Eden New Life, we or us: Eden New Life, a company incorporated in Scotland with registered number SC839384;

     

  • UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended;

     

  • User or you: any third party that accesses the Website and is not either (i) employed by Eden New Life and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Eden New Life accessing the Website in connection with the provision of such services; and

     

  • Website: the website that you are currently using, www.edennew.life, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

     

  1. In this privacy policy, unless the context requires a different interpretation:

    a. the singular includes the plural and vice versa;

    b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

    c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

    d. "including" is understood to mean "including without limitation";

    e. reference to any statutory provision includes any modification or amendment of it;

    f. the headings and sub-headings do not form part of this privacy policy.

     

Scope of this privacy policy

  1. This privacy policy applies only to the actions of Eden New Life and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

     

  2. For purposes of the applicable Data Protection Laws, Eden New Life is the "data controller". This means that Eden New Life determines the purposes for which, and the manner in which, your Data is processed. Overall accountability for our data governance is held by our designated Senior Responsible Individual (SRI).

     

Data collected

  1. We may collect the following Data, which includes personal Data, from you:

    a. name;

    b. date of birth;

    c. sex assigned at birth and presenting gender;

    d. job title;

    e. profession;

    f. contact Information such as email addresses and telephone numbers;

    g. demographic information such as postcode, preferences and interests;

    h. financial information such as credit / debit card numbers;

    i. IP address (automatically collected);

    j. web browser type and version (automatically collected);

    k. operating system (automatically collected);

    l. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

    m. account details, contact details, correspondence and communications data, ID and biographical information, health and social information, including health and medical records, clinical notes, gender identity information, and audio/video recordings of consultations, sensitive information, information about your next of kin and carers, your marketing preferences, location data, technical data, usage data and payment and financial information;

    in each case, in accordance with this privacy policy.

     

How we collect Data

  1. We collect Data in the following ways:

    a. data is given to us by you; and

    b. data is collected automatically.

     

  2. Eden New Life will collect your Data in a number of ways, for example:

    a. when you contact us through the Website, direct message, chat, e-mail or through any other means;

    b. when you register with us and set up an account to receive our products/services;

    c. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);

    d. when you make payments to us, through this Website or otherwise;

    e. when you elect to receive marketing communications from us;

    f. when you use our services;

    in each case, in accordance with this privacy policy.

     

  3. To the extent that you access the Website, we will collect your Data automatically, for example:

    a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

    b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, see the section below, headed "Cookies".

     

Our use of Data

  1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

    a. internal record keeping;

    b. improvement of our products / services;

    c. contact for market research purposes which may be done using email, telephone, fax or mail;

    d. provision of clinical healthcare services and medical advice;

    e. clinical audit and quality assurance to ensure patient safety;

    in each case, in accordance with this privacy policy.

     

  2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests (including recognised legitimate interests under Data Protection Laws) or clinical duties. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

     

  3. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

     

Who we share Data with

  1. Audio and Video Recordings of Consultations

     

    We record video and audio of all consultations between Users and our health specialists.

    a. Purpose: These recordings are processed for clinical record-keeping, safety, and quality assurance/training purposes.

    b. Legal Basis: We process this data because it is necessary for the provision of healthcare (Article 9(2)(h) of the UK GDPR) and for our legitimate interests in maintaining high clinical standards.

    c. Patient Recording: As set out in our Terms and Conditions, Users are prohibited from recording, livestreaming, or publicly sharing sessions. Our specialists have a reasonable expectation of professional privacy. Any unauthorised public disclosure of a session recording may result in legal action.

    d. Retention: Consultation recordings are stored securely and retained for a period of 10 years in accordance with UK clinical record-keeping standards, after which they are destroyed.

     

12.1 We may share your Data with the following groups of people for the following reasons:

a. our employees, agents and/or professional advisors - to allow you to obtain advice from our independent advisors;

b. third party service providers who provide services to us which require the processing of personal data - such as our patient portal - to help you use our services effectively;

c. third party payment providers who process payments made over the Website - to enable you to purchase services from us;

in each case, in accordance with this privacy policy.

 

Keeping Data secure

  1. We will use technical and organisational measures to safeguard your Data, for example:

    a. access to your account is controlled by a password and a user name that is unique to you;

    b. we store your Data on secure servers;

    c. payment details are encrypted using SSL technology.

     

  2. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: help@edennew.life.

     

  3. For detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.

     

Data retention

  1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

     

  2. Clinical and health records (including consultation recordings) are retained for 10 years in accordance with healthcare regulations and medico-legal requirements. Even if we delete non-clinical Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

     

Your rights

  1. You have the following rights in relation to your Data:

    a. Right to access - the right to request copies of the information we hold about you at any time, or that we modify, update or delete such information. Searches conducted in response to access requests are limited to what is reasonable and proportionate. Where clarification or identity verification is required from you, the statutory timeframe to complete your request is paused ("stop the clock") until that information is provided. We will not charge a fee for access unless your request is vexatious or excessive. Where legally permitted, we may refuse your request, providing reasons why.

    b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

    c. Right to erase - the right to request that we delete or remove your Data from our systems; however, this right does not fully apply to clinical and medical records which we are legally obligated to retain for healthcare and regulatory purposes.

    d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it in certain circumstances.

    e. Right to data portability - the right to request that we move, copy or transfer your Data.

    f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

    g. Right regarding automated decision-making - the right to be informed if automated decision-making or profiling is used, to express your point of view, and to request human intervention where automated processing produces legal or similarly significant effects.

     

  2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data, please contact us via email at help@edennew.life.

     

Data Protection Complaints

  1. If you have any concerns or complaints about how your Data is handled, please lodge your complaint directly with us in the first instance via our dedicated complaints portal at www.edennew.life/complaints or by emailing help@edennew.life. We will acknowledge receipt of your data protection complaint within 30 days and work to investigate and resolve it without undue delay.

     

If you remain dissatisfied with our response or how your complaint was handled, you have the right to refer your complaint to the UK supervisory authority, the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

 

  1. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

     

Transfers outside the United Kingdom and European Economic Area

  1. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA).

     

  2. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g., by way of data transfer agreement incorporating standard contractual clauses or adequacy regulations.

     

  3. To ensure that your Data receives an adequate level of protection, we put in place appropriate safeguards and procedures with third parties we share your Data with.

     

Links to other websites

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for their content. This privacy policy does not extend to your use of such websites.

     

Changes of business ownership and control

  1. Eden New Life may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Eden New Life. Data provided by Users will, where relevant, be transferred along with that part and the new owner will be permitted to use the Data for the purposes for which it was originally supplied.

     

  2. We may also disclose Data to a prospective purchaser of our business or any part of it under appropriate confidentiality safeguards.

     

Cookies

  1. This Website may place and access certain Cookies on your computer to improve your experience of using the Website and to improve our range of services. All Cookies used by this Website are used in accordance with current UK Cookie Law.

     

  2. By using our Website, you give your consent to us placing Cookies on your computer in line with your browser settings and cookie banner preferences.

     

  3. This Website may place Strictly Necessary, Analytical/Performance, and Functionality cookies as detailed in the Cookies Schedule.

     

  4. You can choose to enable, disable, or delete Cookies in your internet browser at any time, though losing some settings may affect website functionality.

     

General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights where we reasonably believe your rights will not be affected.

     

  2. If any court or competent authority finds that any provision of this privacy policy is invalid, illegal or unenforceable, that provision will be deemed deleted without affecting the validity of the remaining provisions.

     

  3. This Agreement will be governed by and interpreted according to the law of Scotland. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Scottish courts.

     

Changes to this privacy policy

  1. Eden New Life reserves the right to change this privacy policy as necessary or required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms on your first use of the Website following alterations. You may contact Eden New Life by email at help@edennew.life.

 

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