Privacy Policy

Last updated: July 2026

Paul Adkins – FACIALENHANCE® Positive Acupuncture, Room 2, Highgrove House, Truro Business Park, Threemilestone, Truro, Cornwall. TR4 9NH 01726 883187

Purpose of this Privacy Policy

The processing of personal data is governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This legislation gives you rights as an individual and places obligations on organisations that hold your personal data.

One of those rights is the right to be informed, which means we must provide you with clear information about how we use, share and store your personal data. This policy sets out how we do that.

Who Are We?

Paul Adkins is the data controller for FACIALENHANCE® — Positive Acupuncture, Room 2, Highgrove House, Truro Business Park, Threemilestone, Truro, Cornwall. TR4 9NH — 01726 883187.

Email: enquiries@facialenhance.co.uk

ICO Registration Number: ZB396482

As data controller, we decide how your personal data is processed and for what purposes.

Whose Information Does This Policy Apply To?

This privacy notice applies to information we collect from:

  • visitors to this website (facialenhance.co.uk);
  • people who enquire about the Facial Enhancement Acupuncture (FEA) online course or our services;
  • practitioners listed in our Find a Practitioner directory;
  • students and alumni who provide testimonials for display on this site;
  • people who subscribe to our newsletter.

This website does not host course content, process course enrolments, or take payments. If you go on to enrol on the FEA course, you will do so on our learning platform, hosted by LearnWorlds, at facialenhance.learnworlds.com. Your data as a student or alumnus is covered by the LearnWorlds Privacy Policy, not this one.

If you are a patient, prospective patient, or former patient of Positive Acupuncture clinic, please see the Positive Acupuncture Privacy Policy for how your clinical data is handled — this policy does not cover patient treatment records.

How Do We Process Your Personal Data?

We comply with our obligations under UK GDPR by:

  • keeping personal data accurate and up to date;
  • storing and destroying data securely;
  • not collecting or retaining excessive amounts of data;
  • protecting personal data from loss, misuse, unauthorised access and disclosure;
  • ensuring appropriate technical measures are in place to protect personal data.

Enquiries and Course Eligibility

Visitors may provide details of their acupuncture background and training by email or online enquiry forms, for example to check eligibility for the FEA course, which is restricted to qualified acupuncturists, regulated healthcare professionals with formal acupuncture training, and final-year acupuncture degree students. We are unable to send or receive encrypted emails, so you should be aware that any emails we send or receive may not be protected in transit. We will monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.

We use enquiry information only to respond to you and, where relevant, to direct you to the correct course on the LearnWorlds platform.

Course Enrolment and Payment

This website does not process course enrolments or take payments. Course purchase, enrolment, payment, and course delivery all take place on our learning platform, hosted by LearnWorlds, a third-party data processor. To review how LearnWorlds and its payment processor handle your data once you proceed to enrol, please see the LearnWorlds Privacy Policy.

Practitioner Listings

With your consent, we upload the practice details you provide on completion of the FEA course to our Find a Practitioner directory on this website. This enables prospective patients to contact you for treatment. Listings can be updated or removed at any time by contacting enquiries@facialenhance.co.uk.

Testimonials

We display personal testimonials of satisfied students on this website and in marketing materials. With your explicit consent, we may use your testimonial, your name and location. If you wish to update or delete your testimonial, please contact enquiries@facialenhance.co.uk.

Complaints

When we receive a complaint, we create a file containing the details of the complaint, which normally includes the identity of the complainant and any other individuals involved.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We may need to disclose the complainant’s identity to the person the complaint is about. If a complainant does not want identifying information to be disclosed, we will try to respect that, but it may not always be possible to handle a complaint on an anonymous basis.

We may need to provide personal information collected in relation to complaints to our insurance company or solicitor, where relevant. Complaint records are retained for two years from closure in a secure environment, accessible only on a need-to-know basis.

Newsletter Subscribers

We maintain records of subscribers to our newsletter, which include occasional offers and updates, only with their explicit consent and for marketing purposes.

We use a third-party provider, MailerLite, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry-standard technologies to help us monitor and improve our communications. Subscribers can unsubscribe at any time via the link in any email footer. For more information, please see the MailerLite Privacy Policy.

Website Users

Hosting

This website is hosted by Siteground.co.uk, run by Siteground Hosting Ltd. For more information about how Siteground processes data, please see their privacy policy.

We use WordPress.org software to publish this site and our blog. For more information about how WordPress.org processes data, please see here.

Analytics

When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Please see our cookie policy for full details.

Cookies

We use website cookies to improve the user experience of our website. Please see our cookie policy for full details. You will be presented with a cookie consent banner on your first visit to the site.

Website Security

We use a third-party service to help maintain the security and performance of our website by limiting repeated login attempts. To deliver this service it processes the IP addresses of visitors to our website; logged IPs are obfuscated (hashed).

Contact Forms and Email

Contact form submissions and email links do not store data on our website; instead, the data is transferred via Simple Mail Transfer Protocol (SMTP). We are unable to send or receive encrypted emails, so you should be aware that any emails we send or receive may not be protected in transit. We will monitor any emails sent to us, including file attachments, for viruses or malicious software.

Comments

If our blog allows visitors to post a comment, you will need to enter a name and email address. Comments will be saved to the website’s database, along with an IP address and the date and time of the comment. This information is used for identification purposes only and is not passed onto third parties. Personal identifying information should not be entered by visitors on this website.

Should you wish to have a comment removed, please contact us with the email address you used to upload it at enquiries@facialenhance.co.uk.

Student and Alumni Community

This website does not provide a discussion forum or community area. Enrolled students access the FACIALENHANCE® community within the LearnWorlds platform. Please see the LearnWorlds Privacy Policy for details of how that data is processed.

International Data Transfers

Some of our third-party processors may process data outside the UK. Where this occurs, we ensure that appropriate safeguards are in place, including reliance on the UK’s International Data Transfer Agreement (IDTA) or adequacy decisions where applicable. Please refer to the privacy policies of individual third-party processors for details of the transfer mechanisms they use.

Sharing Your Personal Data

Your personal data will be treated as strictly confidential and shared only in the following circumstances:

  • with named third parties with your explicit consent;
  • with the relevant authority (such as the police or a court) if necessary to comply with a legal obligation;
  • with our insurance company in the event of a complaint or insurance claim;
  • with our solicitor in the event of any investigation or legal proceedings.

For further information about when data may be shared, please see the ICO website.

How Long Do We Keep Your Personal Data?

We keep your personal data for no longer than reasonably necessary.

  • Enquiry correspondence is kept only as long as needed to respond to you and for a reasonable follow-up period.
  • Practitioner directory listings and testimonials are kept until you ask us to update or remove them.
  • Newsletter subscriber data is kept until you unsubscribe or we no longer have a lawful basis to hold it.
  • Complaint records are retained for 2 years from closure.
  • Google Analytics data is automatically deleted after 26 months.

We regularly review the data we hold and will securely delete or anonymise personal data that is no longer required.

Records relating to your course enrolment, attendance, and payments are held on the LearnWorlds platform — see the LearnWorlds Privacy Policy for those retention periods.

Your Rights

Under UK GDPR, unless subject to an exemption, you have the following rights in respect of your personal data:

  • The right to request a copy of the personal data we hold about you.
  • The right to request that we correct any inaccurate or out-of-date personal data.
  • The right to request erasure of your personal data where it is no longer necessary for us to retain it.
  • The right to withdraw your consent to processing at any time (where processing is based on consent).
  • The right to data portability — to receive your data in a structured, commonly used format and, where technically feasible, to have it transferred to another controller (where processing is based on consent or contract and carried out by automated means).
  • The right to request a restriction on further processing where there is a dispute about the accuracy or lawfulness of processing.
  • The right to object to processing (where processing is based on legitimate interests, or for direct marketing purposes).
  • The right to be informed if your data is lost. We will also inform the Information Commissioner’s Office (ICO) in accordance with the timeframes set out in UK GDPR.
  • The right to lodge a complaint with the ICO.

For further details about these rights, please see the ICO website.

Complaints and the ICO

If you have a concern about how we handle your personal data, please contact us in the first instance using the details below. We will acknowledge your concern within 30 days and work to resolve it.

If you remain unsatisfied, you 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.

Further Processing

If we wish to use your personal data for a new purpose not covered by this Privacy Policy, we will provide you with a new notice explaining the new use prior to commencing the processing. Where necessary, we will seek your prior consent.

Lawful Basis for Processing

Under UK GDPR, we process your personal data on the following lawful bases:

  • Consent: displaying your testimonial, adding you to our practitioner directory, and sending marketing emails is done only with your explicit consent.
  • Legitimate interests: we may process enquiry and contact data for the purpose of responding to you, improving our services, and managing complaints, where this does not override your rights and interests.
  • Legal obligation: retaining complaint records where required for insurance or legal purposes.

Contact Details

To exercise any of your rights, or if you have queries or complaints, please contact:

Paul Adkins – FACIALENHANCE® Positive Acupuncture, Room 2, Highgrove House, Truro Business Park, Threemilestone, Truro, Cornwall. TR4 9NH Tel: 01726 883187 Email: enquiries@facialenhance.co.uk

Changes to This Privacy Policy

Any changes made to this Privacy Policy will be posted on this page and, where appropriate, notified to you by email. The “Last updated” date at the top of this document will be revised accordingly. Please check back periodically to see any updates.