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WEBSITE & MARKETING PRIVACY NOTICE
WE RESPECT YOUR PRIVACY AND ARE COMMITTED TO PROTECTING YOUR PERSONAL DATA.
Welcome to The Pain And Injury Clinic’s Website and Marketing Privacy Notice.
The Pain And Injury Clinic, Warwickshire Limited and The Pain And Injury Clinic, Birmingham Limited respect your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This document is intended to cover the data privacy and data handling practices of The Pain And Injury Clinic, Warwickshire Limited and The Pain And Injury Clinic, Birmingham Limited, both which will be referred to as simply ‘The Pain And Injury Clinic’ throughout.
1. IMPORTANT INFORMATION AND WHO WE ARE.
PURPOSE OF THIS PRIVACY NOTICE.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Pain And Injury Clinic is the controller and responsible for your personal data (collectively referred to as “The Pain And Injury Clinic Limited”, “The Pain And Injury Clinic, Warwickshire, Limited”, “The Pain And Injury Clinic, Birmingham, Limited” “we”, “us” or “our” in this privacy notice).
The Pain And Injury Clinic operates the website: www.paininjuryrelief.co.uk
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
CONTACT DETAILS FOR THE WARWICKSHIRE CLINIC.
CONTACT DETAILS FOR THE BIRMINGHAM CLINIC.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name.
- Contact Data includes email address.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
- Direct interactions. You may give us your Identity and Contact Data by contacting us or requesting marketing to be sent to you;
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.
Cookies are small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser which will offer guidance. For more information about how we collect Cookies, please see our Cookies Policy.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Identity and Contact Data from Cliniko, our electronic medical record and diary system when you book an appointment via our Online Booking Calendar based within Cliniko.
- Technical Data from the following parties:
- analytics providers such as Google Analytics based outside the EU;
- advertising networks such as Facebook based outside the EU]; Twitter based outside the EU and Instagram based outside the EU (if you have accessed our webside via one of these platforms).
- search information providers such as Google based outside the EU.
4. HOW WE USE YOUR PERSONAL DATA.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
- Where you have given us consent. Consent means that you have given us clear consent for us to process your data for a specific purpose. You have the right to withdraw consent to marketing at any time by contacting us.
- Where we need to comply with a legal or regulatory obligation. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
- Legitimate interests. We rely on the legitimate interest basis to process your data in the following circumstances:
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). This is necessary for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorgan
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. This is necessary to study how individuals use our website, to develop our website, to grow our business and to inform our strategy.
- To use data analytics to improve our website, services, marketing, users relationships and experiences. This is necessary to define types of users for our services, to keep our website updated and relevant, to develop and inform our strategy.
- To respond to queries made through the website. This is necessary to be able to provide you with a response to your query.
- Consent. We rely on your consent to process your data in the following circumstances:
- To send you marketing material when you have signed up to receive our newsletter.
- To send to a booking confirmation via email, together with a telephone call from one of our reception staff (in order to tell you about your appointment, and allow you to ask any questions), when you make an appointment via our Online Booking Calendar.
- Legal or regulatory obligation
- We also rely on the legal or regulatory obligation ground to process your data in some circumstances. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Please contact us if you would like more details about the specific legal ground we are relying on to process your personal data.
- Opting out: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
For more information about the cookies we use, please see our Cookies Policy on our website.
CHANGE OF PURPOSE.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
EXTERNAL THIRD PARTIES
- Service providers based in UK who provide IT, system administration services and e-marketing on the Pain And Injury Clinic Limited’s behalf.
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield that requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.