1.Data Controller

R’Eagle Minds Ltd
Trading as Freo Wellbeing and Keiru Retreat
The Old Court House
New Road Avenue
Chatham
Kent
ME4 6BE
United Kingdom

Email: mediamanager@freowellbeing.com

R’Eagle Minds Ltd is the Data Controller responsible for Your Personal Data.

2. Information We Collect

A. Personal Information

We may collect:

• Full name

• Email address

• Phone number

• Country of residence

• Booking details

• Payment-related information (processed securely via third-party providers)

• Communications You send to Us

Freo Wellbeing and Keiru Retreat operate under the same Data Controller (R’Eagle Minds Ltd). Information may be shared internally where necessary to provide services.

B. Health and Wellness Information (Special Category Data)

As Keiru Retreat offers wellness and mental wellbeing experiences, We may collect limited health-related information necessary to:

• Assess suitability for retreat participation

• Ensure participant safety

• Accommodate dietary or medical needs

• Support mental wellbeing considerations

This information is classified as Special Category Data under Article 9 UK/EU GDPR and is handled with enhanced protection.

C. Account Data

Where accounts or booking systems are used, these may be managed by secure third-party providers. We receive only the information necessary to administer bookings and provide services.

D. Technical Information

We may process basic technical data (such as IP address and browser type) for website security and operational purposes.

We do not run advertising tracking technologies and do not sell personal data.

3. Lawful Basis for Processing

We process Personal Data under the following lawful bases:

• Contractual necessity – to provide retreat and wellness services

• Legitimate interests – to manage and improve our services

• Legal obligation – to comply with regulatory requirements

• Consent – where required, including for health-related information

For health-related data, We rely on:

• Explicit consent (Article 9(2)(a))

• Provision of health or wellness services (Article 9(2)(h)), where applicable

You may withdraw consent at any time by contacting Us.

4. How We Use Your Information

We use Your information to:

• Manage retreat bookings

• Assess suitability and safety

• Communicate important retreat information

• Provide wellness services

• Respond to enquiries

• Fulfil legal and safeguarding responsibilities

We do not sell or rent Your personal information.

5. International Transfers

As Freo Wellbeing serves international clients, Your data may be processed outside the UK or EEA.

Where transfers occur, We ensure appropriate safeguards are in place, including:

• UK International Data Transfer Agreements (IDTA)

• EU Standard Contractual Clauses (SCCs)

• Transfers to countries with recognised adequacy decisions

6. Data Retention

We retain Personal Data only for as long as necessary to:

• Deliver retreat services

• Comply with legal obligations

• Protect participant safety

• Resolve disputes

Health-related data is retained only as long as required for service delivery and regulatory compliance.

7. Your Rights

Under UK and EU GDPR, You have the right to:

• Access Your personal data

• Correct inaccurate data

• Request deletion

• Restrict or object to processing

• Withdraw consent

• Request data portability

• Lodge a complaint with a supervisory authority

UK residents may contact the Information Commissioner’s Office (ICO): www.ico.org.uk

To exercise Your rights, contact: digital-security-tech@freowellbeing.com

8. Data Security

We implement appropriate technical and organisational measures to protect Your data, including secure booking systems, restricted access controls, and encrypted communications where appropriate.

However, no method of electronic transmission is completely secure.

9. Children

Keiru Retreat is not intended for individuals under 18 years of age. We do not knowingly collect data from minors.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last updated” date.

11. Contact Us

If You have questions about this Privacy Policy or how We handle Your data, please contact:

Email: digital-security-tech@freowellbeing.com