Privacy policy

Last updated: June 2026

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.Normal text.

Who Are We?

Paul Adkins is the data controller for FACIALENHANCE® and the Facial Enhancement Acupuncture (FEA) online training course.
Positive Acupuncture, Room 2, Highgrove House, Truro Business Park, Threemilestone, Truro, Cornwall. TR4 9NH
Tel: 01726 883187
Email: paul@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:

  • online students and alumni of the FEA course;
  • people who enquire about the course or our services;
  • people who subscribe to our newsletters;
  • visitors to this website (facialenhance.learnworlds.com).

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.

Online Training

Sections 1–6 apply to our online students and alumni.
Storage: We keep your data only as long as necessary to fulfil our contractual obligations towards you and as required by UK tax laws.
Platform: Our online training portal is hosted by LearnWorlds, a third-party data processor. This means that identity, contact, transaction and technical data is processed by LearnWorlds. To review how LearnWorlds processes data, please see the LearnWorlds Privacy Policy and their Data Processing Agreement.

1. Identity and Contact Details

Your first and last name and email address are required to register on the online training portal, for the performance of the contract with you, and to manage payments. We will also use this information to notify you about changes to our Privacy Policy and for updates to our services.

Your billing address is required for purchase of the course. These details are used for payment management and are not stored by us beyond our legal retention obligations.

2. Transaction Data

Details about the purchases you make are required to manage and deliver your course access.

3. Financial Data

Payments are processed by a third-party payment processor via the LearnWorlds platform. To review how payments are processed, please see the LearnWorlds payment documentation.

4. Technical Data

Your login credentials (username and password) are required to create an account, purchase securely, and fulfil your order.

5. Email Communications

We may use your identity and contact details to send you emails regarding your studies and follow-up information. 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 will only send you marketing materials with your explicit consent. See ‘Newsletter Subscribers’ below.

6. Eligibility Information

Some students and prospective students may provide details of their acupuncture background and training by email or online enquiry forms. This information is required to verify eligibility for the FEA course, which is restricted to qualified acupuncturists, regulated healthcare professionals with formal acupuncture training, and final-year acupuncture degree students. The same email security caveats apply as set out in section 5 above.

Attendance and Completion Records

We keep a permanent record of students enrolled on the FEA online training course to maintain a record of when you undertook the course, for tax purposes, and to secure potential evidence in the event of a complaint, insurance claim, or legal proceedings. This record is held securely for 7 years after your most recent training, in line with the requirements of relevant professional bodies and our insurers.

Practitioner Listings

With your consent, we may upload the practice details you provide on completion of the course to the FACIALENHANCE® 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 the FACIALENHANCE® 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 Subscibers

We maintain records of subscribers to our newsletters, 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

Sections below apply to visitors to facialenhance.learnworlds.com.

Analytics

When someone visits our website, we use a third-party service 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. 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.

Contact Forms and Email

Contact form submissions and email links do not store data on our website. 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.

Editing and Updating Your Personal Information 

Registered users can access their personal information for editing or updating purposes via the LearnWorlds online portal, once logged in with their username and password.

International Data Trasfers

LearnWorlds and some of our other 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.

  • Attendance and payment records are kept for 6 years in line with HMRC regulations.
  • Your account on LearnWorlds will remain active throughout your course. After your course ends, your account will be deactivated, but your participation record will be retained for academic record-keeping and regulatory purposes.
  • Basic information about online purchases (contact, identity, financial and transaction data) is kept for 6 years after your last purchase, for tax purposes
  • Complaint records are retained for 2 years from closure.


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

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:

  • Contract: processing your name, contact details, and payment information is necessary to perform the contract with you for course access.
  • Consent: sending marketing emails, displaying testimonials, and adding you to our practitioner directory is done only with your explicit consent.
  • Legal obligation: retaining financial and attendance records is required by HMRC and our insurers.
  • Legitimate interests: we may process data for the purpose of improving our services, managing complaints, and maintaining course security, where this does not override your rights and interests.

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: paul@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.

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