Grace Health and Fitness understands that your personal data is entrusted to us and appreciates the importance of protecting and respecting your privacy. To this end we comply fully with the data protection law in force in the UK (“Data Protection Laws”).
This Privacy Policy sets out the basis on which we collect and process personal data about you including our practices regarding the collection, use, storage and disclosure of personal data that we collect from you and/or hold about you, and your rights in relation to that data.
Please read the following carefully to understand how we process your personal data. By providing your personal data to us or by using our services, website or other online or digital platform(s) you are accepting or consenting to the practices as described or referred to in this Privacy Policy.
For the purpose of Data Protection Laws, the data controller is Sarah McMinn-sarah.mcminn@hotmail.co.uk
When we refer to ‘we’, ‘us’ and ‘our’, we mean Grace Health and Fitness
.
What personal data may we collect from you?
When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual.
Accordingly, we may hold and use personal data about you as a customer when you visit our website, complete a form, access our services or speak to us.
Personal data we collect from you may include the following:
· information that you give us when you enquire or become a customer (including home address, date of birth, email address and phone number)
· information about medical history and treatment goals from an online screening form
· details of services and/or treatment you have received from us or which have been received from a third party and referred on to us
· information obtained from customer surveys, promotions and competitions that you have entered or taken part in
· information about complaints and incidents
· information you give us when you make a payment to us, such as financial or credit card information
· other information received from other sources, including from your use of websites and other digital platforms we operate or the other services we provide, information from business partners, advertising networks, analytics providers, or information provided by other companies who have obtained your permission to share information about you.
Where you use our website, we may automatically collect personal data about you including:
· Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,
· Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction
information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
The data that we request from you may include special category data. This includes information that relates to the following:
· racial or ethnic origin, or
· political opinions, or
· religious or philosophical beliefs, or
· genetic data, biometric data for the purpose of uniquely identifying a natural person, or
· health data,
· or data concerning a natural person’s sex life or sexual orientation.
When do we collect personal data about you?
We may collect personal data about you if you:
· visit our website
· enquire about any of our services or treatments
· register to be a customer or book to receive any of our services or treatments
· fill in a form or survey for us
· carry out a transaction on our website
· participate in a competition or promotion or other marketing activity
· make online payments
· contact us, for example by email, telephone or social media
· participate in interactive features on any of our websites
· when you attend a class or session
How do we lawfully process your personal data?
Your personal data will be kept confidential and secure and will only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws, clinical records retention periods and clinical confidentiality guidelines.
Set out below are some of the ways in which we process personal data although to do so lawfully we need to have a legal ground for doing so. We normally process personal data if it is:
· necessary to provide you with our services – to enable us to carry out our obligations to you arising from any contract entered into between us and you including relating to the provision by us of services or treatments to you and related matter such as billing, accounting and audit, credit or other payment card verification and anti-fraud screening
· required or allowed by any applicable law
· with your explicit consent for example: direct consumer marketing communications.
Generally, we will only ask for your consent to processing if there is no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained.
To process special category data we rely on additional legal grounds and generally, they are as follows:
· With your explicit consent
· It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, clinical concerns, regulatory breaches or investigations e.g the Care Quality Commission or GMC or ICO.
Processing of personal data which you have made public:
As stated above, one of the legal grounds for processing data is where it is in our legitimate interest to do so, taking into account your interest’s rights and freedoms. This allows us to manage the relationship that exists between you and us and can include the following reasons:
· provide you with information, products or services that you request from us
· managing all aspects of our relationship with you, our products and services
· allow you to participate in interactive features of our services, when you choose to do so
· notify you about changes to our products or services
· keep our records up to date
· respond to requests where we have a legal or regulatory obligation to do so
· check the accuracy of information about you and the quality of your treatment
· assess the quality and/or type of service you have received (including giving you the opportunity to complete customer satisfaction surveys) and any concerns or complaints you may raise, so that these can be properly investigated
· to conduct and analyse market research
· to ensure that content from any of our websites is presented in the most effective manner for you and for your computer
· to allow us to enforce our website terms of use, our policy terms and conditions or other contracts, or to protect our or other’s rights, property or safety
· to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations including to defend ourselves from claims, exercise our rights and adhere to laws and regulations that apply to us
· to personalise the marketing emails we send you, where you have consented to us doing so
The security of your personal data
We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged.
Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.
Personal data that we collect from you may be transferred to, and stored at, a destination outside of the UK and the European Economic Area (“EEA”). Where we transfer your personal data outside the EEA, we will ensure that there are adequate protections in place for your rights, in accordance with Data Protection Laws. By submitting your personal data, and in providing any personal data to us, you understand the basis for this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.
All information you provide to us is stored securely. Any payment transactions on our website will be processed securely by third party payment processors. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we will use strict procedures and security features to minimise the risk of unauthorised access.
At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information
transmission; if you choose to send or receive such information via email, you do so understanding the risks associated with doing so.
How long do we retain your personal data?
Unless we explain otherwise to you, we will retain your personal data on the basis of the following guidelines:
· for as long as we have a reasonable business need, such as managing our relationship with you and managing our business
· for as long as we provide services and/or treatment to you and then for as long as someone could bring a claim against us (in general this is a period of 8 years); and/or
· in line with legal and regulatory requirements or guidance.
Disclosure of your personal data to third parties
In the usual course of our business we may disclose your personal data (which will be limited to the extent reasonably necessary) to certain third party organisations that we use to support the delivery of our services. This may include the following:
· business partners, suppliers and sub-contractors for the performance of any contract we enter into with you,
· organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
· delivery companies for the purposes of transportation,
· third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to having an appropriate lawful basis for such processing.
Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.
Special Category/Health information collected during provision of treatment or services
Special category data (including information relating to your health) will only be disclosed to third parties in accordance with this Privacy Policy. That includes third parties involved with your treatment or care, or in accordance with UK laws and guidelines of appropriate professional bodies.
External practitioners: If we refer you externally for treatment, we will share with the person or organisation that we refer you to, the clinical and administrative information we consider necessary for that referral. It will always be clear when we do this.
Your GP: If by treating you we believe it to be clinically advisable, we may also share information about your treatment with your GP. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous and/or detrimental to your health to deny your GP full information about your medical history, and we strongly advise against it.
What do we do with any non-personal information collected when accessing the website?
Certain information which you submit may also be collected to enable us to better understand our customers, to improve our website, to inform general marketing and to help provide a better experience of our services. We may use cookies to do this.
We may also use other companies to set cookies on our websites and gather cookie information for us – please refer to the information detailed below. From time to time we may also analyse Internet Protocol (IP) addresses or other anonymous data sources.
Marketing
If you have consented to our processing your personal data for marketing purposes, in accordance with this Privacy Policy, we may send you information (via mail, email, phone or SMS) about our products and services which we consider may be of interest to you. You have the right to opt out of receiving any further marketing communication at any time.
Your Rights under Data Protection Laws
The law gives you certain rights in respect of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. The website of the Information Commissioner’s Office (http://www.ico.org.uk) has a wealth of useful information in respect of your rights in your personal data. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights.
· Data Subject Access Request – With some exceptions designed to protect the rights of others you have the right to a copy of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
· The Right of Erasure (‘Right to be Forgotten’) – the right to have your personal information erased where we have no reason to continue processing;
· Data Portability – the right to move, copy or transfer personal information you have provided to us;
· Right to Rectification – You have the right to have the personal data we hold about you corrected if it is factually inaccurate. If any of your personal data has changed, especially contact information such as: email address, postal address and phone number please get in touch with us so we can ensure your personal data is kept up to date.
If you want to exercise your rights in respect of your personal data, the best way to do so is to contact us by email on sarah.mcminn@hotmail.co.uk
If you are not satisfied with how we handle your request, you can contact the Information Commissioner’s Office on 0303 123 1113 or visit their website (http://www.ico.org.uk).
Changes to our Privacy Policy
We keep our Privacy Policy under regular review and as a result it may be amended from time to time without notice. As a result we encourage you to review this Privacy Policy regularly. This Privacy Policy was last updated in Dec 2020.
Contact
If you have any questions in relation to our privacy policy, please email us at sarah.mcminn@hotmail.co.uk
Cookies
Our websites use cookies to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites.
By law, website operators are required to ask for a website user’s permission when placing certain kinds of cookie on their devices for the first time.
Where consent is required, the law states that it should be “informed consent”, which means we must ensure that you understand what cookies are and why we want to use them.
We are committed to providing the best digital service to you whilst at the same time fully protecting your privacy. For further information on our cookies policy and how we use cookies through use of all our online services, please see below.
What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience.
They can also help to ensure that adverts you see online are more relevant to you and your interests.
Category 1 Cookies
These cookies are essential in order to enable you to move around our websites and use its features, such as accessing secure areas of the websites. Without these cookies, services you have asked for cannot be provided.
Your consent is not required for the delivery of those cookies which are strictly necessary to provide services requested by you.
We use these types of cookies.
Category 2 Cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All the information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Web analytics that use cookies to gather data to enhance the performance of a website fall into this category. For example, they may be used for testing designs and ensuring a consistent look and feel is maintained for the user. This category does not include cookies used for behavioral/ targeted advertising networks.
We use these types of cookies. By using our website and online services you agree that we can place these types of cookies on your device.
Category 3 Cookies
These cookies allow our websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect is generally anonymised and they cannot track your browsing activity on other websites.
We use these types of cookies. By using our websites these you agree that we can place these types of cookies on your device.
Category 4 Cookies
These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
We use these types of cookies. By using our website and online services you agree that we can place these types of cookies on your device.
Definitions used above are consistent with those supplied by the International Chamber of Commerce ‘ICC UK Cookie Guide’ April 2012.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.
For more information on our position on the use of cookies, please contact us at sarah.mcminn@hotmail.co.uk
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential Category 1 Cookies) you may not be able to access all or parts of our websites. For information on how to delete cookies, please refer to: use https://ico.org.uk/for-the-public/online/cookies