PRIVACY POLICY
Introduction
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This policy sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice “process” means to collect, store, transfer, use or otherwise act on any information.
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We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
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We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
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Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org.
Other than as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
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1. OUR BUSINESS
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Massage and Wellbeing Ltd, based at 18 Gandy Street, Exeter, EX4 3LS, which hereafter for the purposes of this Privacy Policy will be referred to as Massage and Wellbeing.
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2. WHO WE ARE
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Massage and Wellbeing provides therapy practice rooms, which are hired out to self-employed practitioners who provide therapeutic treatments for health conditions in accordance with their individual professional body codes of practice and professional indemnity insurance.
Massage and Wellbeing supports the hiring of therapy practice rooms by providing booking facilities to therapists and their customers.
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3. HOW THE LAW PROTECTS YOU
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Data protection laws state that we are only able to process personal data if we have valid reasons to do so. The basis for processing your personal data includes, but is not limited to, information we process with your consent, information we process because we have a contractual obligation, and information we process because we have a legal obligation.
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1. Information we process with your consent
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Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website, make a booking with a therapist, or ask us to provide you with more information about our business, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected therapists operating from our facilities whom we consider may provide services you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at info@massageandwellbeing.co.uk. However, if you do so, you may not be able to use our website or our services further.
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2. Information we process because we have a contractual obligation
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When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
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verify your identity for security purposes
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sell products to you
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provide you with our services
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provide you with suggestions and advice on products, services and how to obtain the most from using our website
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We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
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3. Information we process because we have a legal obligation
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We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
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4. PERSONAL DATA WE PROCESS
How we obtain personal data.
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The information we process about you includes information:
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you have directly provided to us
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that we gather from third party databases and service providers as a result of monitoring how you use our website or our services
Types of personal data we collect directly
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When you use our website, our services or buy from us, for example, when you create an account on our website, we ask you to provide personal data. This can be categorised into the following groups:
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personal identifiers, such as your first and last names
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contact information, such as your email address and your telephone number
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account information, including your username and password
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records of communication between us, including messages sent through our website, email messages and telephone conversations
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marketing preferences that tell us what types of marketing you would like to receive
Types of personal data we collect from your use of our services
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By using our website and our services, we process:
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your username and password and other information used to access our website and our services
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information you contribute to our community, including reviews
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your replies to polls and surveys
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technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
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usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
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transaction information that includes the details of the products services you have bought from us and payments made to us for those services
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your preferences to receive marketing from us, how you wish to communicate with us, and responses and actions in relation to your use of our services
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transaction information that includes the details of the products services you have bought from us and payments made to us for those services
All self-employed therapy practitioners making use of Massage and Wellbeing facilities handle customer personal and medical data individually in accordance with their own GDPR privacy policies and may request further consent. Whilst self-employed therapy practitioners manage their own data in accordance with their own privacy policies, Massage and Wellbeing will still require personal details including; contact details such as first and last names telephone numbers, email addresses. This information is used to manage bookings, record clients entry onto the premises for fire regulation. Personal details may be used to remind you of future appointments, clinical auditing and for accountancy purposes.
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Massage and Wellbeing may request additional details from our practitioners. Where this is required, we will only do so if we are under a legal obligation to comply.
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For marketing purposes, Massage and Wellbeing may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
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In making initial contact with Massage and Wellbeing you consent to us maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Massage and Wellbeing may occasionally also act in the capacity of data processor, when we may promote other self-employed therapy practitioners operating from our premises. Massage and Wellbeing does not broker your data and you can ask to be removed from our marketing database by contacting us using the details provided at the end of this Privacy Policy.
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Massage and Wellbeing’s website is hosted by Webhealer.net and use cookies, which are strings of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Webhealer.net uses cookies to help Massage and Wellbeing identify and track visitors and their website access preferences. Massage and Wellbeing’s website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Massage and Wellbeing’s website. Massage and Wellbeing’s 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 statements of every website you visit.
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Payments through our website are administered by Stripe. At the point of payment, you are transferred to a secure page on the website and credit/debit card payment is taken via the Stripe payment gateway. No payment details are kept on our website or servers. All payment data is fully secure and safe and processed through Stripe who is fully PCI compliant.
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5. CONSENT
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By agreeing to this Privacy Policy you are consenting to Massage and Wellbeing processing your personal data for the purposes outlined. You can withdraw consent at any time by using the contact details provided at the end of this Privacy Policy.
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6. DISCLOSURE
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Massage and Wellbeing will keep your personal information safe and secure. Only self-employed therapy practitioners directly engaged in providing your treatment will retain and have access to your treatment records although our administration team will have access to your contact details so that they can make appointments and manage your account. Massage and Wellbeing will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. Massage and Wellbeing may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
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7. RETENTION POLICY
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Massage and Wellbeing, except as otherwise mentioned in this privacy notice, will keep and process your personal data only for as long as required by us to provide you with the services you have requested, and will continue to store only the personal data needed after the contract has expired to meet any legal obligations. After this time period all personal data will be deleted unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
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8. THIRD PARTY DATA PROCESSORS & DATA STORAGE
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We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and, to the best of our belief and understanding, all of them comply with current GDPR legislation. The following third parties are based in the USA where we have signed Standard EU contractual clauses for data transfers between EU and non-EU countries in place or the services are privacy shield protected.
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Google (Privacy policy)
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Acuity Scheduling (Privacy policy)
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Mailchimp (Privacy policy)
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Stripe (Privacy policy)
We do not currently make use of any UK-based data processors, but in such future eventuality, we will ensure GDPR data protection agreements have been put in place.
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9. YOUR RIGHTS AS A DATA SUBJECT
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At any point whilst Massage and Wellbeing are in possession of, or processing your personal data, all data subjects have the following rights:
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Right of access – you have the right to request a copy of the information that we hold about you.
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Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
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Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
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Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
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Right of portability – you have the right to have the data we hold about you transferred to another organisation.
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Right to object – you have the right to object to certain types of processing such as direct marketing.
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Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Massage and Wellbeing refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Massage and Wellbeing can confirm what information it holds about you and how it is processed.
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10. YOU CAN REQUEST THE FOLLOWING INFORMATION:
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Identity and the contact details of the person or organisation (Massage and Wellbeing) that has determined how and why to process your data.
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Contact details of the data protection officer, where applicable.
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The purpose of the processing as well as the legal basis for processing.
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If the processing is based on the legitimate interests of Massage and Wellbeing and information about these interests.
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The categories of personal data collected, stored and processed.
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Recipient(s) or categories of recipients that the data is/will be disclosed to.
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How long the data will be stored.
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Details of your rights to correct, erasure, restrict or object to such processing.
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Information about your right to withdraw consent at any time.
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How to lodge a complaint with the supervisory authority (ICO).
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Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
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The source of personal data if it wasn’t collected directly from you.
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Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
11. TO ACCESS WHAT PERSONAL DATA IS HELD, IDENTIFICATION WILL BE REQUIRED
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Massage and Wellbeing will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Massage and Wellbeing is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to info@massageandwellbeing.co.uk, by phoning 07887891218 or writing to us at:
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Massage and Wellbeing
18 Gandy Street
Exeter
EX4 3LS
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12. CHANGES TO OUR PRIVACY POLICY
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This Privacy Policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.
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13. COMPLAINTS
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In the event that you wish to make a complaint about how your personal data is being processed by Massage and Wellbeing you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
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The details for each of these contacts are:
Michelle Hollox, Carly Pickering or Adam Kocinski
Telephone 07887891218 or email: info@massageandwellbeing.co.uk
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ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/