Privacy Policy

Last updated: May 2026

Version: 4.0

Definitions

Company: Freedom The Dialysis Holiday Specialist Ltd, a limited company registered in England and Wales (Company No. 02045508).

UK GDPR: The UK General Data Protection Regulation, as retained in UK law by the European Union (Withdrawal) Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

DPA: The Data Protection Act 2018.

ICO: The Information Commissioner’s Office, the UK’s independent data protection regulator.

Personal Data: Any information relating to an identified or identifiable living individual.

Processing: Any operation performed on personal data, including collection, storage, use, disclosure or deletion.

 

Introduction

The privacy and security of your personal information is extremely important to us. We want everyone who comes to us for support using our service to feel confident and comfortable that any personal information they share with us will be looked after.

This privacy policy explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.

Freedom The Dialysis Holiday Specialist Ltd needs to keep certain information about its users in order to carry out its day-to-day operations, meet its objectives and comply with legal obligations.

We are committed to protecting individuals’ personal information and privacy, and ensuring any personal data is handled in line with the UK GDPR and the DPA 2018. Personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

We will never sell your personal data and will only share it with trusted third-party organisations when it is necessary to deliver our services and where the privacy and security of your data is assured — for example, for the purpose of your Dialysis Away From Base (DAFB) arrangements between your holiday unit and home unit.

If you have any questions about this privacy policy or how we use your personal data, please contact our Data Protection Officer:

•          Email: info@holidaydialysis.co.uk

•          Post: Data Protection Officer, Freedom The Dialysis Holiday Specialist Ltd, 2 Back Lane, Cossington, Leicester LE7 4UQ

•          Telephone: 01509 815999

 

1. Who We Are

Freedom The Dialysis Holiday Specialist Ltd is a limited company registered in England and Wales (Company No. 02045508). We provide a holiday support service for Dialysis Away From Base (DAFB) both in the UK and internationally.

We are committed to improving access to DAFB for kidney patients and their families.

For the purposes of UK data protection law, Freedom The Dialysis Holiday Specialist Ltd is the Data Controller in respect of your personal data.

 

2. What Personal Data Do We Collect?

We collect or update your personal information every time you get in touch with us by post, email, telephone, through our website, face to face, or occasionally via social media. Personal information includes any information which identifies you, or which can be identified as relating to you personally, such as your name, address, phone number and email address.

We will only collect, use and otherwise handle your personal data:

•          Where you have given your consent for specific, explicit and legitimate purposes;

•          Where it is necessary to fulfil a contract with you, or to take steps at your request before entering into a contract;

•          Where this is necessary to fulfil legal obligations that apply to us; or

•          Where it is necessary for our legitimate interests in running our day-to-day operations, provided those interests are not overridden by your rights and freedoms.

 

Sensitive (Special Category) Personal Data

As part of our services, we may collect sensitive personal data such as information about your health condition and social circumstances. This information is only collected in order to deliver the best possible service to you. It is always stored securely and is not shared more widely than necessary within the company.

We will not pass on your details to anyone else without your express permission, except in exceptional circumstances — for example, where there is a serious safeguarding concern, a risk of harm to yourself or others, or in order to comply with a legal obligation.

Where you have given us your express consent to share your story, we may publish it on our website, social media or other media.

Legal basis for processing: Explicit consent (Article 9(2)(a) UK GDPR)

Online Communities and Social Media

We may obtain personal data through your use of social media platforms such as Facebook, Instagram, X (formerly Twitter) and others, depending on your account settings and the privacy policies of those platforms. To change your settings, please refer to the relevant platform’s privacy notice.

Legal basis for processing: Consent

Email Newsletter

We use a third-party provider, Mailchimp (operated by Intuit Inc.), to deliver our e-newsletters. We collect statistics on email opening and click rates using industry-standard technologies to improve our communications. For further information, please see Mailchimp’s privacy notice at mailchimp.com/legal/privacy.

Legal basis for processing: Explicit consent

Website and Cookies

Our website uses cookies — small text files placed on your device — to help us improve your experience. Cookies allow us to analyse web traffic, remember your preferences, and identify how our pages are used. A cookie does not give us access to your computer or any information about you beyond what you choose to share.

In accordance with the Privacy and Electronic Communications Regulations (PECR), we will ask for your consent before placing non-essential cookies on your device. You can also manage or withdraw cookie consent at any time through your browser settings or our cookie preference centre on the website.

We use the following types of cookies:

•          Strictly necessary cookies: Required for the website to function and cannot be switched off.

•          Analytical/performance cookies: Help us understand how visitors interact with our website (e.g. Google Analytics).

•          Functionality cookies: Remember your preferences to personalise your experience.

Legal basis for processing: Consent (non-essential cookies); Legitimate interests (strictly necessary cookies)

 

3. Children and Young People

When we know a client is under 18, we will always seek consent from a parent or guardian before storing and using their personal information. Communications will be directed to the parent or guardian unless we have their express permission to communicate directly with the child or young person.

If you believe we have inadvertently collected personal data from a minor without appropriate consent, please contact us immediately at info@holidaydialysis.co.uk so that we can take appropriate action.

Legal basis for processing: Explicit consent from parent/guardian

 

4. How We Use Your Personal Data

We use the personal information we collect to help us deliver our international DAFB services to patients and their families, build strong client relationships, tailor our communications, and meet our legal, statutory and regulatory obligations. Specific purposes include:

•          To provide you with services, products or information you have requested, or which we believe may be of interest to you;

•          To fulfil our service of DAFB arrangements on your behalf;

•          To notify you of changes to our services;

•          To analyse and improve our work, services, activities, products and website;

•          To manage our website, including monitoring usage, blocking disruptive access, and personalising content;

•          For administration and record-keeping purposes;

•          For fraud prevention, credit risk reduction, or as otherwise required by law or regulation;

•          To comply with our legal and regulatory obligations.

Research and Feedback

We may carry out research with our customers and staff to gather feedback and improve our services. Participation is always voluntary and you can choose not to take part. Where research involves sensitive personal data (such as ethnicity), this is entirely optional and a ‘prefer not to say’ option is always provided. Your personal details will be anonymised for any reporting purposes.

We may share limited personal data (such as contact information) with a carefully selected research agency under a non-disclosure agreement or equivalent data processing agreement, solely for the purposes of carrying out research on our behalf.

 

5. Keeping Your Information Safe

We take the security of your personal data seriously. We have implemented appropriate technical and organisational measures to protect your data against unauthorised access, loss, alteration or disclosure. Our information security arrangements are reviewed at least annually.

We will never sell or share your personal data with third-party organisations for their own marketing purposes. Where we engage third-party processors to handle data on our behalf, we ensure they are bound by a data processing agreement, store data securely, delete it when no longer needed, and use it only for the specific purpose authorised by us.

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements, such as use of the UK’s International Data Transfer Agreement (IDTA) or equivalent adequacy arrangements.

 

6. How Long We Keep Your Data

We will only retain your personal data for as long as is necessary for the purposes for which it was collected, including to satisfy any legal, regulatory, accounting or reporting requirements.

The specific retention period will depend on the nature of the data and the purpose for which it is held. In general:

•          Client records relating to DAFB arrangements are retained for a minimum of 7 years following the last service provided, in line with our legal and contractual obligations.

•          Marketing data is retained until you withdraw your consent or opt out.

•          Website analytics data is typically retained for no more than 26 months.

If you would like further information about our retention periods, please contact our Data Protection Officer.

 

7. Your Rights

Under the UK GDPR and DPA 2018, you have the following rights in relation to your personal data:

•          Right of access — You can request a copy of the personal data we hold about you (a ‘Subject Access Request’).

•          Right to rectification — You can ask us to correct inaccurate or incomplete personal data.

•          Right to erasure — You can ask us to delete your personal data in certain circumstances (‘the right to be forgotten’).

•          Right to restriction of processing — You can ask us to limit how we use your data in certain circumstances.

•          Right to object — You can object to our processing of your data where we rely on legitimate interests as our legal basis.

•          Right to data portability — You can request that your personal data be transferred to you or another organisation in a structured, machine-readable format, where technically feasible.

•          Right to withdraw consent — Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

•          Rights in relation to automated decision-making — You have the right not to be subject to solely automated decisions that have a significant effect on you, except in limited circumstances.

You will not be charged for exercising your rights. We will respond to requests within one calendar month. If your request is complex or numerous, we may extend this by a further two months, in which case we will notify you.

To exercise any of the above rights, please contact us using the details below.

 

8. Updating Your Details and Marketing Preferences

If at any time you wish to update, amend or remove your personal data or marketing preferences, please contact us in one of the following ways:

•          Email: info@holidaydialysis.co.uk

•          Website: www.holidaydialysis.co.uk

•          Telephone: 01509 815999

•          Post: Data Protection Officer, Freedom The Dialysis Holiday Specialist Ltd, 2 Back Lane, Cossington, Leicester LE7 4UQ

•          Click the unsubscribe or ‘update my preferences’ link at the bottom of any email we send you.

 

9. How to Make a Complaint

If you have any concerns about how we handle your personal information, please contact us in the first instance:

•          Email: info@holidaydialysis.co.uk

•          Post: Data Protection Officer, Freedom The Dialysis Holiday Specialist Ltd, 2 Back Lane, Cossington, Leicester LE7 4UQ

•          Telephone: 01509 815999

If you remain dissatisfied after contacting us, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection:

•          Website: https://www.ico.org.uk

•          Telephone: 0303 123 1113

•          Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

10. Changes to This Policy

We review this privacy policy at least once a year to ensure it remains up to date and accurate. Any changes will be posted on our website. For significant changes, we will notify you by email where we hold your contact details.

We encourage you to review this policy periodically. Continued use of our services after changes are posted constitutes your acknowledgement of the updated policy.

For feedback on this policy, please contact us at info@holidaydialysis.co.uk.

 

Freedom The Dialysis Holiday Specialist Ltd • Company No. 02045508 • Privacy Policy v4.0 • May 2026

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