Terms & Conditions, & DPIA


  • R’Eagle Minds Ltd (Trading as Freo Wellbeing / Keiru Retreat)

    1. Description of Processing

    We collect and process personal and health-related data to:

    • Facilitate retreat bookings

    • Assess participant suitability

    • Provide wellness and mental wellbeing services

    • Ensure participant safety

    Special category data processed includes:

    • Mental wellbeing disclosures

    • Health conditions

    • Dietary or medical requirements

    Processing occurs via secure third-party booking/account platforms.

    2. Purpose of Processing

    • Delivery of contracted wellness services

    • Participant safeguarding

    • Risk management

    • Legal compliance

    3. Lawful Basis

    Article 6 UK/EU GDPR:

    • Contractual necessity

    • Legitimate interests

    • Legal obligation

    • Consent

    Article 9 UK/EU GDPR (Special Category Data):

    • Explicit consent

    • Provision of health/wellness services

    4. Necessity & Proportionality

    • Only data necessary for retreat safety and administration is collected

    • Health data is limited to relevant information

    • Data minimisation principles applied

    • Access restricted to authorised personnel

    5. Risks to Individuals

    Potential risks:

    • Data breach of mental health information

    • Misuse or over-collection of sensitive data

    • Reputational harm

    • Emotional distress

    • Cross-border transfer risk

    6. Measures to Mitigate Risk

    • Secure third-party providers

    • Contractual Data Processing Agreements

    • Encrypted storage where applicable

    • Limited internal access controls

    • Clear consent mechanisms

    • Defined retention limits

    • Staff confidentiality obligations

    7. Residual Risk Assessment

    After mitigation, risk is considered:

    Low to Moderate
    No automated decision-making
    No profiling
    No sale of data

    8. Review Schedule

    This DPIA will be reviewed annually or upon:

    • Introduction of new technology

    • Expansion into new jurisdictions

    • Change in health data processing scope

  • Legal

    These terms and conditions outline the rules and regulations for the use of Keiru Retreat's Website, located at www.keiru-retreat.com.

    By accessing this website we assume that you accept these terms and conditions. Do not continue to use Keiru Retreat if you do not agree to all of the terms and conditions stated on this page.

    This website (“website”) is owned and operated by R’Eagle Minds Ltd, acting on behalf of Keiru Retreat, The Old Court House, New Road Avenue, Chatham, Kent, United Kingdom, ME4 6BE, UK. The terms “Keiru Retreat”, “we”, “us”, “our”, “ours” and “ourselves” mean Keiru Retreat, which includes, its parent, subsidiaries, divisions, branches, affiliates or companies under common ownership or control of Keiru Retreat. The terms “client”, “you”, “your” and “yours” when used in these Terms and Conditions mean any user of this website, whether as a guest or registered user. "Party", "Parties", or "Us", refers to both the Client and ourselves.

    The website is controlled by Keiru Retreat. These terms and conditions are governed by the law of England and all actions or proceedings arising out of or relating to these Terms and Conditions may be addressed in England. We retain the right to bring legal proceedings in any jurisdiction where we believe that breach of this agreement is taking place or originating.

    Acceptance

    All terms refer to the offer, acceptance and consideration of payment necessary to undertake the process of our assistance to the Client in the most appropriate manner for the express purpose of meeting the Client’s needs.

    Please read these Terms and Conditions and the accompanying Privacy Policy carefully.

    Access to and use of this website and the information, materials, program and services available through this website are subject to these Terms and Conditions and to all other applicable laws and regulations. Access to and use of the information, and materials provided is not intended, and is prohibited, where such access or use violates all such applicable laws or regulations.

    By accessing this website, you agree to these Terms and Conditions. If you do not agree, please exit this website.

    These Terms and Conditions may be changed by us from time to time and we will post them on the website. Your use of this website is conditional on agreeing to the terms and conditions in force at the time.

    Cookies

    We employ the use of cookies. By accessing Keiru Retreat, you agreed to use cookies in agreement with the Keiru Retreat's Privacy Policy.

    Most interactive websites use cookies to let us retrieve the user’s details for each visit. Cookies are used by our website to enable the functionality of certain areas to make it easier for people visiting our website. Some of our affiliate/advertising partners may also use cookies.

    Your Privacy

    All Personal Data provided to us as a result of this website will be handled in accordance with our DPIA and Privacy Policy. Please click here for more detail.

    By agreeing to these Terms and Conditions, you acknowledge you have read and understood the terms of our Privacy Policy and that you agree with it.

    Keiru Retreat takes your privacy and confidentiality very seriously. Our system is GDPR and HIPPA compliant, and we have invested heavily in our online security environment. All the communication between you and your specialists are done via a secure internet connection and all clients create their own secure portal via secure password log-in.

    All our specialists operate with the same systems and we have additionally implemented managerial, electronic and physical measures (i.e biometric scanning), to ensure all medical data and client/specialist correspondence are safeguarded. Each of our clients needs to provide a valid email address by which you will be notified of any specialist responses to your messages or queries. The email will notify you of a response which you will then be able to check through your secure log-in. For armed forces personnel, neither your Commander or any other member of your platoon will be able to access your information.

    Exceptions to the Privacy Policy become valid should you become suicidal, homicidal or acutely unwell to the point where you need in-patient or more specialised treatment which we are unable to provide remotely. Depending on the circumstances we will then notify you, your family doctor, your Army Chaplain, Platoon Commander or Local Health Authority who will assist you further.

    If you also feel that you need face-to-face counselling or treatment, you can inform us and we will refer you where we are able, and/or advise you accordingly.

    Our aim is to respond to your needs within 48 hours.

    Licence

    Unless otherwise stated, Keiru Retreat and/or its licensors own the intellectual property rights for all material on Keiru Retreat. All intellectual property rights are reserved. You may access this from Keiru Retreat for your own personal use subjected to restrictions set in these terms and conditions.

    You must not:

    • Republish material from Keiru Retreat without sourcing, linking back and/or credit

    • Sell, rent or sub-license material from Keiru Retreat.

    • Reproduce, duplicate or copy material from Keiru Retreat.

    • Redistribute content fromKeiru Retreat without sourcing, linking back and/or credit.

    This Agreement shall begin on the date hereof.

    Parts of this website may offer an opportunity for users to post and exchange opinions and information in certain areas of the website. Keiru Retreat may not filter, edit, publish or review Comments prior to their presence on the website. Comments do not reflect the views and opinions of Keiru Retreat, its agents and/or affiliates. Comments reflect the views and opinions of the persons who post their views and opinions. To the extent permitted by applicable laws, Keiru Retreat shall not be liable for the Comments or for any liability, damages or expenses caused and/or suffered as a result of any use of and/or posting of and/or appearance of the Comments on this website.

    Keiru Retreat reserves the right to monitor all Comments and to remove any Comments which can be considered inappropriate, offensive or causes breach of these Terms and Conditions.

    You warrant and represent that:

    • You are entitled to post the Comments on our website and have all necessary licenses and consents to do so;

    • The Comments do not invade any intellectual property right, including without limitation copyright, patent or trademark of any third party;

    • The Comments do not contain any defamatory, libelous, offensive, indecent or otherwise unlawful material which is an invasion of privacy

    • The Comments will not be used to solicit or promote business or custom or present commercial activities or unlawful activity.

    • You hereby grant Keiru Retreat a non-exclusive license to use, reproduce, edit and authorize others to use, reproduce and edit any of your Comments in any and all forms, formats or media.

    Content Hyperlinks

    The following organisations may link to our Website without prior written approval:

    Government agencies; Search engines; News organisations; Online directory distributors may link to our Website in the same manner as they hyperlink to the Websites of other listed businesses; and System wide Accredited Businesses except soliciting non-profit organisations, charity shopping malls, and charity fundraising groups which may not hyperlink to our Website.

    These organisations may link to our home page, to publications or to other Website information so long as the link: (a) is not in any way deceptive; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products and/or services; and (c) fits within the context of the linking party’s site.

    We may consider and approve other link requests from the following types of organisations:

    • commonly-known consumer and/or business information sources; dot.com community sites; associations or other groups representing charities; online directory distributors; internet portals; accounting, law and consulting firms; and educational institutions and trade associations.

    We will approve link requests from these organisations if we decide that:

    • (a) the link would not make us look unfavourably to ourselves or to our accredited businesses;

    • (b) the organisation does not have any negative records with us;

    • (c) the benefit to us from the visibility of the hyperlink compensates the absence of Keiru Retreat; and

    • (d) the link is in the context of general resource information.

    These organisations may link to our home page so long as the link:

    • (a) is not in any way deceptive;

    • (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products or services; and

    • (c) fits within the context of the linking party’s site.

    If you are one of the organisations listed in paragraph 2 above and are interested in linking to our website, you must inform us by sending an email to Keiru Retreat. Please include your name, your organisation name, contact information as well as the URL of your site, a list of any URLs from which you intend to link to our Website, and a list of the URLs on our site to which you would like to link. Wait 2-3 weeks for a response.

    Approved organisations may hyperlink to our Website as follows:

    • By use of our corporate name; or

    • By use of the uniform resource locator being linked to; or

    • By use of any other description of our Website being linked to that makes sense within the context and format of content on the linking party’s site.

    No use of Keiru Retreat's logo or other artwork will be allowed for linking absent a trademark license agreement.

    Reservation of Rights

    We reserve the right to request that you remove all links or any particular link to our Website. You approve to immediately remove all links to our Website upon request. We also reserve the right to amend these terms and conditions and it’s linking policy at any time. By continuously linking to our Website, you agree to be bound to and follow these linking terms and conditions.

    Removal of Links from Our Website

    If you find any link on our Website that is offensive for any reason, you are free to contact and inform us any moment. We will consider requests to remove links but we are not obligated to or so or to respond to you directly.

    While we endeavour to keep all information as accurate and up to date as possible, and we take all possible action to ensure our website is available at all times, we do not guarantee its completeness; nor do we promise to ensure that the website remains available or that all of the material on the website is kept up to date. We reserve the right to suspend access to the whole or part of our website in order to modify, delete, edit, make repairs.

    Disclaimer

    To the maximum extent permitted by applicable law, we exclude all representations, warranties and conditions relating to our website and the use of this website. Nothing in this disclaimer will:

    • limit or exclude our or your liability for death or personal injury;

    • limit or exclude our or your liability for fraud or fraudulent misrepresentation;

    • limit any of our or your liabilities in any way that is not permitted under applicable law; or

    • exclude any of our or your liabilities that may not be excluded under applicable law.

    The limitations and prohibitions of liability set in this Section and elsewhere in this disclaimer:

    • (a) are subject to the preceding paragraph; and

    • (b) govern all liabilities arising under the disclaimer, including liabilities arising in contract, in tort and for breach of statutory duty.

    As long as the website and the information and services on the website are provided free of charge, we will not be liable for any loss or damage of any nature.

    Contact

    If you have any questions regarding these Terms and Conditions or any other matters concerning the website, feel free to email us at enquiries@keiru-retreat.com. We endeavour to respond to all communications as soon as possible.