DATA PROTECTION NOTICE FOR YOWIE LIMITED

Welcome to the Yowie Limited privacy notice. Complete Massage Chelmsford, Complete Chiropractic, Chelmsford Sports Therapy and the UK Scoliosis Clinic are trading names of Yowie Limited.

The purpose of this document is to explain what data we collect and hold when you become a customer, and what rights you have under the law.

Please remember that it is your responsibility to read any updates to this privacy policy, which will be emailed to you or posted on our websites.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy if required.

PURPOSE OF NOTICE

This privacy notice aims to give you information on how we collect and processes your personal data at our clinic, through your use of our websites and other contact channels, or when you purchase a product.

This privacy notice supplements our other policy documents, and is designed to complement them, not to override them.

CONTACT

To contact us in relation to your data protection rights, please

Email:  complaince@completechiropractic.co.uk

Or write:

Yowie Limited

88 Broomfield Road,

Chelmsford, Essex,

CM1 1SS

DATA CONTROLLER

Yowie Limited is the controller and responsible for your personal data

(collectedly referred to as “Yowie”, “we”, “us” or “our” in this privacy notice).  Yowie Limited trades as “Complete Chiropractic” “Chelmsford Sports Therapy” and “The UK Scoliosis Clinic.”

This policy notice covers the entirety of Yowie Limited’s operations.

At this time Yowie has not appointed a data protection officer, as the scale of our operations falls well below the required threshold.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 8th May 2018 and historic versions can be obtained by request.

If you are a Yowie client, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

Please take extra care to ensure that we have up to date contact details for you (a working email address is sufficient). To comply with best practice, if we are unable to contact you for a period of more then two years, any data we hold in relation to you will be deleted.

THIRD-PARTY LINKS

Our web sites, emails or other forms of communication may include links or add-ons from/ to third-party Yowie, 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 Yowie and are not responsible for their privacy statements. When you leave our websites, we suggest that you should read the privacy notice of every websites you visit.

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: 

may include first name, last name, username or similar identifier, and company name.

Contact Data:

may include billing address, delivery address, email address and telephone numbers.

Transaction Data:

may include details about payments to and from you (e.g. invoices) and other details of products and services you have purchased from us.

Financial Data:

may include bank account and references to payment cards (although we never store any actual payment card informa9on ourselves, we use a third party provider to keep this secure).

Usage Data:

May include information about how you use our websites, products and services.

Marketing data:

May include an email address you provide for marketing or information communications (which may not be the same as your contact email address) as well as your preferences in this regard.

Yowie also collects and uses 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 websites 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.

DATA WE COLLECT ABOUT CHILDREN

Under the GDPR regulation, Children are defined as individuals under the age of 18. Children under 13 are considered unable to give consent for their data to be processed, therefore we must seek permission from a responsible parent or guardian.

Children over 13 are able to give consent, however we strongly advise that children under the age of 18 discuss this document with their parent or guardian before accessing our services.

Our websites is not intended for children under the age of 13, and we do not knowingly collect data relating to children from our Website. We encourage parents to supervise their children at all times while online.

Children have the same rights to data protection as adults – of course they also have the right to be made aware of these rights. For this reason, Yowie Ltd. Provides a simplified version of the fundamental rights outlined in this document, which is suitable for younger children.

This document is provided as an act of good faith to aid understanding and should in no way be considered to be a legally binding document.

A child over 13 signing this document, or an adult signing on behalf of a child under 18 shall be deemed sufficient to have granted consent to its contents.

Where we collect data about children we will not collect any more data than is outlined in this document, although we may collect less.

In addition to our normal policy on data retention the General Chiropractic Council requires us to store records relating to children until his or her 25th birthday, or 26th birthday if the patient was 17 at the conclusion of treatment.

SPECIAL DATA

In order to provide our services to you, we will collect some information about your health. In this privacy notice this has been categorised as medical data.

Medical data:

May include information about your condition, pain and disability questionnaires, patient records, x rays, posture scans or photographs and any other information, such as test results, images or scans which we record in order to tailor your treatment to you.

We do not usually ask for information relating to your race or ethnicity, although in some instances this may be pertinent to your condition, if this is the case, we’ll explain why, and we will include this information under this heading.

Other than your medical data, we do not collect any Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions,

trade union membership). Nor do we collect any information about criminal convictions and offences.

Other than that data necessary for the provision of treatment, we will not ask for data on any of these issues at any time. Please do not provide us with this data – any data of this nature which you choose to provide or provide inadvertently and is not related to your care will be deleted immediately.

IF YOU CHOOSE NOT TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we

have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us your Identity, or Contact data by filling in forms or

by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing or information to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or intercoms.

As you interact with our websites, 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.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

  • Analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as worldpay based outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

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 we need to provide the goods and services we have agreed to provide to you.
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • To provide you with updates to our services, special offers or marketing communications (if you opt in)

You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

The table below explains the ways we plan to use your personal

data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose

Type of Data

Basis for processing & Legitimate interest
     
     

To register you as a new customer

Identity

Performance of our services for you.
 

Contact

Ensuring suitability of treatment.
 

Medical

  
     
     

To take payment for services -including:

Identity

Performance of our services for you.

1. Managing payments, fees and charges

Contact

Legitimate interest to recover due debts.

2. Collecting money owed to us

Financial

  

3. Taking payment for a treatment package

Transaction

  
 

Marketing

  
     
     

To ensure that your treatment is appropriate

Identity

Ensuring suitability of treatment

including:

Medical

  

1. Reviewing your treatment history

    

2. Discussing treatment with other healthcare providers,

    

if you have asked us to do so

    
     
     

To manage our relationship with you including:

Identity

Performance of our services for you.

1. Notifying you of policy changes

Contact

Necessary to comply with legal obligation.

2. Notifying you of changes to fees

    

3. Notifying you of changes to practice hours etc.

    
     
     

To improve our products through data analytics

Identity

Legitimate interest to understand our customer base,
 

Transaction

keep our services and websites up to date
 

Usage

develop our marketing & growth strategy

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and information communications.

You will receive marketing communications from us if you have opted in to paper, or email-based information, such special offers and our newsletter.

You will not receive marketing if you do not opt in. You can opt into receiving information form us by post at the bottom of this form. If you wish to receive our email newsletter, you can sign up for this on our website.

OPTING OUT

You can ask us to step sending you marketing or information messages at any time. For printed materials, please contact us.

To opt out of our email updates, please click the “unsubscribe” link, which will be included with all of our emails.

Please note that if choose not to receive news, updates, special offers or information from us we will still use your contact information in delivering the products or services which you have purchased from us.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when we set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly.

CHANGE OF PURPOSE

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.

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.

DISCLOSURES OF YOUR PERSONAL DATA

Sometimes we will need to transfer data to third parties, such as insurance providers or your doctor.

If we need to transfer your data, or you ask us to, we will either:

  • Disclose your data and transfer it in line with existing agreements with the third party (usually the case for insurance companies)
  • Contact you for further information about what data you would like disclosed and in what way.
  • Provide data to you, so that you may carry out the disclosure and transfer yourself.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring 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.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We are not able to transfer data to nations which are not considered to afford subjects sufficient protection – although we can provide you with a copy of your data which you may transfer at your own risk.

DATA SECURITY

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.

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.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. For most data, this means we will hold your data for as long as you are a current client, and then for 2 years after your last appointment. After 2 years (or as soon as you ask us to) will delete your data.

The General chiropractic council requires us to retain your Medical data for 8 years following your last visit. Since we are required to retain this data, special conditions apply to our ability to delete it before 8 years has passed. Special conditions apply for children, see above. Please contact us for more information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to  object to processing (see below), where we may have inadvertently processed your information unlawfully or  where we are required to erase your personal data to comply with local law.Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

In the event that your decision to object to processing means that we are unable to provide you with a product or service, you accept that we cannot be held liable for breach of contract.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • (a) if you want us to establish the data’s accuracy;
    • (b) where our use of the data is unlawful, but you do not want us to erase it;
    • (c) where you need or wish us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • 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 wish to exercise any of the rights set out above, please contact us.

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. Additionally, if you make a specific request relating to format (for example, you would like a copy X-ray on film, rather than digital) we reserve the right to charge a reasonable fee to cover our costs in complying with your request.  Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

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 several requests. In this case, we will notify you and keep you updated.