PRIVACY POLICY

1.     IMPORTANT INFORMATION AND WHO WE ARE

INTRODUCTION

Welcome to With Grace Frome’s (“With Grace”) Privacy Policy.

With Grace respects your privacy and is committed to protecting your personal data. This privacy policy aims to provide you with clear information as to how we at With Grace collect and process your personal data through your use of our website https://www.withgracefrome.co.uk (“Website”), including any data you may provide through this Website when you:

-        complete an online consultation form with us;

-        purchase a product or service from the Website; or

-        sign up to receive news on our products, services and promotions;

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 Policy together with any other privacy policy or fair processing policy 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 Policy supplements other notices and privacy policies we may publish or send to you from time to time and is not intended to override them.

CONTROLLER

With Grace is the controller and responsible for your personal data (collectively referred to as “we”, “us”, or “our” in this Privacy Policy).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests please contact our Data Privacy Manager using the details below.

CONTACT DETAILS

If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Privacy Manager in the following ways:

Full name of legal entity: Grace Hempshall t/a [With Grace Frome] [Massage with Grace]

Email address: appointmentwithgrace@gmail.com

Postal address: 3 Magnolia Close, Frome, Somerset, BA11 2TT

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 POLICY AND YOUR DUTY TO INFROM US OF CHANGES

We keep our Privacy Policy under regular review. It is important that any personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD – PARTY LINKS

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 policy of every other website you visit.

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 as follows:

·       Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.

·       Contact Data includes billing address, delivery address, email address and telephone numbers.

·       Financial Data includes bank account and payment card details.

·       Transaction Data includes details about payments to and from you and other details of products and / or services you have purchased from us.

·       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.

·       Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

·       Usage Data includes information about how you use our Website, products and services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

·       Health Data includes information you provide via consultation forms to tell us about your medical conditions and or medication to enable us to treat you safely and effectively.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

IF YOU FAIL 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 into with you (for example, we may need specific Health data to enable us to safely treat you and provide our services to you). In this case, we may have to cancel any pre-arranged appointment you have with us but we will notify you if this is the case at the time and give you an opportunity to provide us with the necessary information.

3.     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, Contact, Financial and Health 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;

•       complete a consultation form;

•       create an account on our Website;

•       subscribe to our service or publications;

•       request marketing to be sent to you;

•       enter a competition, promotion or survey; or

•       give us feedback or contact us.

•       Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

•       Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below

•       Identity and Health Data:

All our data records are stored electronically using Cliniko Software, a well-regarded practice management software system for clinicians and health practitioners. Cliniko is GDPR compliant and you can find further details on how they comprehensively tread personal data here: https://www.cliniko.com/security/. Mailchimp is used to manage the With Grace Newsletter.

•       Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [NAME] based [inside OR 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 we need to perform the contract we are about to enter into or have entered into with you.

•       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.

•       Where we need to comply with a legal obligation.

In some cases we will rely on your express consent as a legal basis for processing your personal data and we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA (“PERMITTED PURPOSES”)

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases 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/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer and record completed consultation forms.

(a)   Identity

(b)   Contact

(c)   Health

(a)   Performance of a contract with you.

(b)   Necessary for our legitimate interests (to enable us to safely provide our service to you).

(c)   Express consent is required from you for us to collect Health data at the time you complete your consultation form.

To process and deliver your our products and / or services :

(a)   Manage payments, fees and charges.

(b)   Collect and recover money owed to us.

(a)   Identity

(b)   Contact

(c)   Financial

(d)   Transaction

(e)   Marketing and Communications

(a)   Performance of a contract with you.

(b)   Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include:

(a)   Notifying you about changes to our terms or privacy policy.

(b)   Asking you to leave a review or take a survey.

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Marketing and Communications.

(a)   Performance of a contract with you.

(b)   Necessary to comply with a legal obligation.

(c)   Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

To enable you to partake in a prize draw, competition or complete a survey.

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(a)   Performance of a contract with you.

(b)   Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a)   Identity

(b)   Contact

(c)   Technical

(a)    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

(b)    Necessary to comply with a legal obligation.

To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(f)     Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.

(a)   Technical

(b)   Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).

To make suggestions and recommendations to you about goods or services that may be of interest to you.

(a)   Identity

(b)   Contact

(c)   Technical

(d)   Usage

(e)   Profile

(f)     Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business).

MARKETING AND PROMOTIONAL OFFERS FROM US

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

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time [by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences OR 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 product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website 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.

5.     DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the above in Section 4 under Purposes for which we will use your personal data.

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

We do not transfer your personal data outside the European Economic Area (EEA). We may transfer your personal data abroad if required for the Permitted Purposes as described above. 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 which 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.

7.     DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, stolen, 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.

In addition as mentioned, all our data records and notes are stored electronically using Cliniko Software and whenever data is sent to Cliniko it is encrypted using HTTPS (end-to-end encryption). Cliniko use a 2048-bit SSL cerification for encryption in transit.

8.     HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements (including any obligations we have to retain data imposed by the Federation of Holistic Therapists). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

9.     YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data and we will deal with you requests in a manner that is consistent with applicable law. Some of the rights you may have 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 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 (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 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.

•       Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o   If you want us to establish the data’s accuracy.

o   Where our use of the data is unlawful but you do not want us to erase it.

o   Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

o   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.

•       Right to 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. 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 could 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 could 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.