Policy version: June 2022
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
|Category of data||In more detail|
|Identify and account data you input into the Services
|Data collected when you use specific functions in the Services||Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)|
|Other data the Services collects automatically when you use it||
If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
We collect sensitive data from patients of the clinic during consultations and this information is stored in a separate, secure practice management system.
If, however you submit sensitive data to us in any other manner than during a consultation, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) or you provide it in one of the forms on our website, we will assume that you have purposefully made any such sensitive data manifestly public.
We collect personal data from you directly when you submit a form on our website, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or when you attend a therapy session with one of our therapists or indirectly, such as your activity while using the Services.
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
|What we use your personal data for||Our reasons|
|Create and manage your patient file with us||To perform our contract with you or to take steps at your request before entering into a contract|
|Providing services and/or the functionalities of the Services to you||Depending on the circumstances:
|To enforce legal rights or defend or undertake legal proceedings||Depending on the circumstances:
|Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices||Depending on the circumstances:
|Protect the security of systems and data||To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us|
|Operational reasons, such as improving efficiency, training, and quality control or to provide support to you||For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you|
|Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, website and functionalities and offerings or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our website|
|Updating and enhancing user records||Depending on the circumstances:
|Depending on the circumstances:
||To comply with our legal and regulatory obligations|
|To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary
|Depending on the circumstances:
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We intended to use email marketing to inform you of our services such as promotions and to run surveys and competitions.
We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers and cloud storage providers and providers of practice management services. We exert no control over their privacy policies.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
Personal data which you provide via a form on our website is kept for 6 months. Patient records are kept for up to 7 years after you cease to be a patient of the clinic, to comply with any professional, accounting or legal obligations including in the event of the pursuit or defence of legal claims.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
|Access to a copy of your personal data||The right to be provided with a copy of your personal data.|
|Correction (also known as rectification)||The right to require us to correct any mistakes in your personal data.|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data—in certain situations.|
|Restriction of use||The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.|
|To object to use||The right to object:
|Not to be subject to decisions without human involvement||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, call or write to us—see below: ‘How to contact us’. When contacting us please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Our contact details are shown below: