WEBSITE AND MARKETING PRIVACY NOTICE
The clinic respects 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 privacy notice aims to give you information on how Cleckheaton Chiropractic Clinic collects and processes your personal data through your use of this website, including any data you may provide through this website, for example when you contact us.
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 Clinic operates the website: www.cleckheatonchiropractic.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.
Name or title of Data Privacy Manager: Amit Raju
Address: Cleckheaton Chiropractic Clinic, Charlotte Court, Law Street, Cleckheaton, BD19 3QR
Please contact the clinics data privacy manager in writing first so we have the chance to deal with your concerns in the first instance. You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ().
Changes to the privacy notice and your duty to inform us of changes
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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).
· Identity Data includes first name, last name.
· Contact Data includes email address.
· Technical Data includes IP address, browser type and version, 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.
· 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.]
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 competition organisers who collect your data when you enter a competition for example
· Technical Data from the following parties:
1. 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.
o 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.
2. Where you have given us consent
o 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.
3. Where we need to comply with a legal or regulatory obligation.
o 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
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 reorganisation or a restructuring exercise.
· 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.
We rely on your consent to process your data in the following circumstances
• To send you marketing material when you have signed up to be on our communication database.[LE2]
3. 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.
For more information about the cookies we use, please see our Cookies Policy on our website.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
External Third Parties:
o Service providers based in UK who provide IT, system administration services and e-marketing on the Cleckheaton Chiropractic’s behalf.
o Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
o 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.
We do not transfer your personal data outside
the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
i. 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.
ii. 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.
iii. 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.
iv. 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.
v. 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.
vi. Request the transfer of your personal information to another party.
vii. 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.
If you want to exercise any of the above rights, please contact Data Privacy Manager in writing.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.