Zerenia Clinic UK

Privacy Policy

Introduction

Zerenia Clinics 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.

 

  1. Important Information and who we are

Purpose of this Privacy Notice

This privacy notice aims to give you information on how Zerenia collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a service or take part in a competition.

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 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.

Controller

Zerenia is the controller and responsible for your personal data (collectively referred to as Zerenia, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact Details

Our full details are:

Trading name: Zerenia

Full name of legal entity: Zerenia Clinics Limited, Mackrell, Savoy Hill House, 7-10 Savoy Hill, London, United Kingdom, WC2R 0BU

Phone Number: 07885837937

Postal address: Zerenia, 9A Wilbraham Pl, Belgravia, London SW1X 9AE

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 Notice and your duty to inform us of changes

This version was created in October 2021.

It is important that the 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 notice of every website you visit.

 

  1. 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 includes first name, maiden name, last name, username or similar identifier, marital status, 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 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.
  • Medical Data This information could include ‘health data’ which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected.

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.

With the exception of Medical Data, we do not collect any other 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.

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, 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.

 

  1. 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 and Financial 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; (through our online form or via our online booking)
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • 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.
  • Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    1. analytics providers such as Google based inside  OR outside the EU;
    2. advertising networks such as Adroll or Affilinet based OR outside the EU; and
    3. search information providers such as Google or Bing based inside OR outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside the EU.
  • Identity and Contact Data from data brokers or aggregators Experian based inside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  1. 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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.

USING YOUR MEDICAL DATA

In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information.  Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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 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/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver our services to you including:

(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

(f) Health information

(a) Performance of a contract with you

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

(c) Necessary for us to provide health care or treatment

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

(e) Health information

(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)

(d) Necessary for us to provide health care or treatment

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

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

MARKETING

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

PROMOTIONAL OFFERS FROM US

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 good or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing..

COOKIES  & WEBTRACKING

 

  1. WHAT ARE COOKIES?

Our site uses cookies to keep track of progress and to provide our visitors with a tailored user experience. With the help of cookies, we can present you with customised content and adverts that will be of more interest to you. We also use cookies to remember your passwords for you so you don’t have to re-enter them each time you visit the site. You have the option of setting your browser to reject cookies. However, if certain cookies that track your details are rejected then we won’t be able to pre-fill any data on the site or direct you to the correct stage on your next visit.

 

  1. COOKIE UPDATE

Zerenia use necessary cookies to make the website easier for you to use and to ensure you get the best experience. If you choose to continue without changing these settings, you consent to this, but should you want to, you can change your settings at any time.

We will only read or write cookies for the preference level set, cookies set prior to you changing your settings will still be on your computer and you can remove them using your browser settings.

We use a cookie to remember your cookie preferences this has a couple of consequences

 

  • If you delete all your cookies you will have to update your preferences with us again.
  • If you use a different device, computer profile or browser you will have to tell us your preferences again.

iii. INFORMATION THIS WEBSITE GATHERS/TRACKS

As web tracking offers more chances to market to website visitors across the Internet, you as a visitor to the Zerenia website may be targeted with adverts on other websites. Google and third party vendors might show targeted adverts with the ability to opt out. First and third party cookies are used to provide information and offer improvements to optimise quality of adverts served. You can change the cookie management settings in your web browser to stop these adverts. If you are a registered Facebook user, you may also receive targeted adverts from Zerenia.

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.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Such third parties consist of:

 

  • IT: Service providers acting as processors who provide IT and system administration services.
  • Advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

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.

 

  1. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

 

  1. 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.

 

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

Zerenia will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

 

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw 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. 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 a number of requests. In this case, we will notify you and keep you updated.

 

  1. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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.

Necessary for us to provide health care or treatment means processing your special categories of personal data (i.e. health data) where it is necessary for the purposes of preventive or occupational medicine, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or UK law or pursuant to contract with a health professional (subject to required conditions and safeguards).

YOUR LEGAL RIGHTS

You have 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 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 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.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it

Zerenia Clinics – Privacy and Cookies Policy

Policy version: October 25th 2021

www.zereniaclinic.co.uk (our platform) is provided by Zerenia Clinics (‘we’, ‘our’ or ‘us’). We are the controller of Personal Data obtained via our platform, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your Personal Data) in connection with your use of our platform. It also explains your rights in relation to your Personal Data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Given

This privacy policy is divided into the following sections:

  • What this policy applies to
  • Personal Data we collect about you
  • Sensitive Personal Data we collect about you
  • How your Personal Data is collected
  • How and why we use your Personal Data
  • Marketing
  • Who we share your Personal Data with
  • How long your Personal Data will be kept
  • Transferring your Personal Data out of the UK
  • Cookies
  • Your rights
  • Keeping your Personal Data secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us

What this policy applies to

This privacy policy relates to your use of our platform only.

Throughout our platform we may link to other websites owned and operated by certain trusted third parties to

Personal data we collect about you

The Personal Data we collect about you depends on the particular activities carried out through our platform. We will collect and use the following Personal Data about you:

  • your name, address and contact information, including email address and telephone number and location
  • information to check and verify your identity, eg date of birth
  • your billing information, transaction and payment card or other payment method information
  • details of any information, feedback or other matters you give to us by phone, email, post or via social media
  • your medical insurance
  • your account details, such as username and login details
  • your activities on, and use of, our platform
  • information about the services we provide to you
  • your contact history, purchase history and saved items
  • information about how you use our platform and technology systems
  • your responses to surveys and questionnaires

Special Category Personal Data or Sensitive Data

Certain Personal Data we collect is treated as a ‘special category’ to which additional protections apply under data protection law. This is also known as ‘Sensitive Data’. Where we process such Sensitive Data, we will also ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent. Sensitive Data we collect about you, where you choose to give it to us, may include:

  • Medical history: past surgeries, past treatments
  • Existing conditions: allergies, chronic pains, chronic illnesses, ongoing treatments such as current medications consumed
  • Records and details prescriptions given and/or refused  
  • Past consultations; dates, the doctor providing treatment and the concern
  • Weight, height, age,
  • your gender and sex – if you choose to give this to us
  • Lifestyle details: hours spent driving and when, interaction with heavy machinery, childcaring
  • Past and present use of cannabis (if any)
  • History of drug consumption, medical or recreational

If you do not provide Personal Data we ask for where it is asked, it will prevent us from providing our services to you as explained in the relevant forms on which such data is collected or insert a link to further information.

We collect and use this Personal Data for the purposes described in the section ‘How and why we use your Personal Data’ below.

How your Personal Data is collected

We collect Personal Data from you:

  • directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase or request services via our platform, post material to our platform and complete patient surveys, and
  • indirectly, such as your browsing activity while on our platform; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies’ below

How and why we use your Personal Data

Under data protection law, we can only use your Personal Data if we have a proper reason, eg:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your Personal Data for and why.

What we use your Personal Data for

Our reasons

Create and manage your account and patient file with us

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you

To perform our contract with you or to take steps at your request before entering into a contract

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us

To comply with our legal and regulatory obligations

For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect our business, interests and rights

Customise our platform and its content to your particular preferences based on a record of your selected preferences or on your use of our platform

Depending on the circumstances:

—your consent as gathered by the tool on our platform – see ‘Cookies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookie tool (this will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn)

Retaining and evaluating information on your recent visits to our platform and how you move around different sections of our platform for analytics purposes to understand how people use our platform so that we can make it more intuitive or to check our platform is working as intended

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our platform—see ‘Cookies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookie tool (this will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn)

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services and/or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you

Protecting the security of systems and data used to provide the services

To comply with our legal and regulatory obligations

We may also use your Personal Data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us understand our patient base

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Updating and enhancing patient records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our patients about existing consultations, services and new services and products

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business

To comply with our legal and regulatory obligations

Marketing our services to existing and former patients

For our legitimate interests, ie to promote our business to existing and former patients

See ‘Marketing’ below for further information

The audit of our accounts and business

For our legitimate interests, ie to maintain any accreditations so we can demonstrate we operate at the highest standards

To share your Personal Data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your Personal Data—sharing

See ‘Who we share your Personal Data with’ for further information on the steps we will take to protect your Personal Data where we need to share it with others.

Marketing

We will use your Personal Data to send you updates by email, text message, telephone or post about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your Personal Data for marketing purposes (see above ‘How and why we use your Personal Data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at [insert contact details for marketing opt-out]
  • using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your Personal Data with the utmost respect and [never sell OR share] it with other organisations outside the Zerenia Clinics group for marketing purposes.

For more information on your right to object at any time to your Personal Data being used for marketing purposes, see ‘Your rights’ below.

Who we share your Personal Data with

We routinely share Personal Data with:

  • third parties we use to help deliver our services to you, eg, third party service providers (such as website developers or payment providers, or providers of security infrastructure)
  • other third parties we use to help us run our business, eg platform hosts and platform analytics providers
  • Freelance Doctors and other medical staff or contractors assisting us in providing their services to you

We only allow those organisations or individuals to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on them to ensure they can only use your Personal Data to provide services to us and to you.

We or the third parties mentioned above occasionally also share Personal Data with:

  • our and their external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your Personal Data will be bound by confidentiality obligations

Who we share your Personal Data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your Personal Data will be kept

We will not keep your Personal Data for longer than we need it for the purpose for which it is used. For example, we will usually keep data for 6 years in order to comply with our legal and tax obligations.

Following the end of the of the relevant retention period, we will delete or anonymise your Personal Data.

Transferring your Personal Data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to share your Personal Data with countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your Personal Data.

We may transfer your Personal Data to our service providers and website and platform hosts located outside the UK

Under data protection laws, we can only transfer your Personal Data to a country outside the UK where:

  • In the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of Personal Data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
  • there are appropriate safeguards in place in the form of Standard Contractual Clauses signed by the party in question, together with enforceable rights and effective legal remedies for you, or
  • a specific exception applies under relevant data protection law

Where we transfer your Personal Data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) on the basis of legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your Personal Data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send Personal Data or in the transfer mechanisms we use to transfer Personal Data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Further information

If you would like further information about data transferred outside the UK please contact us and/or our Data Protection Officer (see ‘How to contact us’ below).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our platform. We use cookies on our platform. These help us recognise you and your device and store some information about your preferences or past actions and allow you to select and view products, place them in the cart on our platform and allow you to proceed to checkout.

Cookies: Consent to use cookies and changing settings

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to keep you logged into your account as you navigate the platform).

You can withdraw any consent to the use of cookies or manage any other cookie preferences by using the tools on any page of our platform and/or interacting with our cookies banner. You can then adjust your settings as appropriate. It may be necessary to refresh the page for the updated settings to take effect.

Our use of cookies

The table below provides more information about the cookies we use on our platform and portal, and why:

The cookies we use

Name

Purpose

Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie

[Describe the type of cookie, including its owner eg ‘Universal Analytics (Google)’]

[Insert cookie name(s) eg _ga, _gali, _gat, _gid]

[Insert a general description, eg: This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.]

This cookie collects [information in an anonymous form including: [insert] OR personal information including: [insert].]

[Insert details of how long the cookie will remain—this should not exceed 13 months from when first accepted.

Read [insert link to third party guidance on how the third party (eg Google or Youtube) uses the cookies and the data generated by them where relevant].

[Insert, eg [Yes, essential (we will therefore not request your consent before placing this cookie) OR No, will therefore request your consent before placing this cookie]]

[Insert details of other cookies]

[Insert details of other cookies]

[Insert details of other cookies]

[Insert details of other cookies]

 

How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies or if you want to change your settings and cookies preferences with us, you can do so at any time via the ‘Cookies button’ on our platform or via your account on our portal. You may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our platform and other sites you visit.

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your Personal Data

The right to be provided with a copy of your Personal Data

Correction (also known as rectification)

The right to require us to correct any mistakes in your Personal Data

Erasure (also known as the right to be forgotten)

The right to require us to delete your Personal Data—in certain situations

Restriction of use

The right to require us to restrict use of your Personal Data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your Personal Data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your Personal Data, eg where we use your Personal Data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our platform

The right to withdraw consents

If you have provided us with a consent to use your Personal Data you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (e.g. your full name, address and patient or matter reference number and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your Personal Data secure

We have appropriate security measures to prevent Personal Data from being accidentally lost, or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

[Insert details of any specific security measure that you wish to mention to reassure data subjects, eg encryption technologies (this is purely optional).]

If you want detailed information from Get Safe Online on how to protect your Personal Data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your Personal Data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our platform for a reasonable period or by updating you via email.How to contact us

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

[Insert contact address]