Privacy policy
How we look after your personal information.
Draft for review. This policy is a starting point written for UK GDPR and the Data Protection Act 2018. Please have it reviewed by a qualified adviser before relying on it. Last updated: [ADD: date].
Who we are
Divine Start provides maternity and newborn care in London, United Kingdom. Divine Start is a trading name of [ADD: registered company name], a company registered in England and Wales (company number [ADD: company number]), whose registered address is [ADD: registered address].
We are the “controller” of the personal information described in this policy. Our ICO registration number is [ADD: ICO registration number – check whether you need to pay the data protection fee at ico.org.uk].
If you have any questions about this policy or your information, email us at [email protected] or call +44 7990 074617.
The information we collect
When you send us an enquiry
Through our website form we collect:
- your name
- your phone number and/or email address
- the service you are interested in
- your due date or your baby’s age, if you choose to give it
- anything you write in your message
To protect the form from spam and abuse, we also store a one-way scrambled (hashed) version of the internet (IP) address your enquiry was sent from. We use this only to limit how many enquiries can be sent in a short time.
When you contact us in other ways
If you call, email or message us on WhatsApp, we will receive your contact details and anything you tell us.
When you become a client
[ADD: what you collect from clients, e.g. home address, details of your care needs, your baby’s name and date of birth, payment details, and any health information you choose to share]
Health information
Information about your health or your baby’s health is “special category” data and needs extra protection. Please don’t include detailed medical information in the website form; we can talk about it privately. Where we need health information to provide care, we will only use it [CONFIRM with your adviser: with your explicit consent and/or where necessary for the provision of health or social care].
How we use your information
- to reply to your enquiry and give you a quote
- to arrange, provide and manage your care and bookings
- to take payments and keep financial records
- to protect our website and services from spam and misuse
- to meet our legal and regulatory obligations
We do not sell your information, and we do not use it for marketing without your permission.
Our lawful bases
- Steps before a contract and performing a contract – when you ask us about our services and when we provide them to you.
- Legitimate interests – to respond to general enquiries and keep our website secure.
- Legal obligation – for example, keeping tax and accounting records.
- Consent – where we ask for it. You can withdraw consent at any time.
Who we share it with
We only share your information with trusted providers who help us run our business:
- Supabase – securely stores the enquiries sent through our website, on servers in the European Union (Frankfurt, Germany).
- Resend – sends us an email alert when a new enquiry arrives.
- Cloudflare – hosts and protects our website.
- Email provider – [ADD: e.g. Google Workspace or Microsoft 365].
- WhatsApp (Meta) – if you choose to message us on WhatsApp.
- Professional advisers such as accountants or insurers, where needed.
- Public authorities, if the law requires it or to protect someone’s safety.
Some of these providers may process information outside the UK. Where they do, we rely on appropriate safeguards such as the UK International Data Transfer Agreement or Addendum, or UK adequacy regulations.
How long we keep it
- Enquiries that don’t lead to a booking: [ADD: e.g. 12 months]
- Client records: [ADD: e.g. 6 years after care ends – check professional and insurance guidance]
- Financial records: as long as required by law (usually 6 years).
Your rights
Under UK data protection law you have the right to:
- ask for a copy of your information
- ask us to correct information that is wrong or incomplete
- ask us to delete your information
- ask us to restrict or stop using your information
- object to how we use your information
- ask us to transfer your information to someone else
- withdraw your consent at any time, where we rely on consent
To use any of these rights, contact us at [email protected]. We will respond within one month.
Cookies and tracking
Our website does not use cookies, advertising trackers or analytics that identify you. If we add privacy-friendly, cookie-free statistics in future (such as Cloudflare Web Analytics), we will update this policy. The private staff sign-in area stores a sign-in token in the browser of staff who log in; it is not used for visitors.
Keeping your information safe
We use secure, access-controlled systems. Enquiries sent through our website can only be read by authorised Divine Start staff.
Complaints
If you are unhappy with how we have used your information, please contact us first so we can try to put things right. You also have the right to complain to the Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint or 0303 123 1113.
Changes to this policy
We may update this policy from time to time. The latest version will always be on this page.
