1.1 Therapy Harley Street Ltd (“Therapy Harley Street” “us”, “we” or “our”), with its registered office at 19 Michael Field, Forest Row, East Sussex RH18 5BH and registered in England and Wales under registration number 9977154, is committed to protecting the privacy of its users.
2 DATA CONTROLLER
2.1 Therapy Harley Street Limited is the data controller (“Data Controller”) for the purposes of the Act and can be contacted at:
Our principal place of business is at 10 Harley Street, London W1G 9PF.
(a) By post, to 19 Michael Field, Forest Row, East Sussex RH18 5BH;
(b) Using our website contact form
(c) By telephone, on the contact number published on our website
(d) By email, using firstname.lastname@example.org
3 OUR COMMITMENT TO PROTECTING YOUR PRIVACY
3.1 Therapy Harley Street is committed to protecting your privacy. The majority of pages s on the Therapy Harley Street Website do not collect any Information.Sometimes we need Information to provide the services to our clients. This document is designed to give you a clear explanation of our data processing policies. Please see below for further information. If you have any questions or concerns relating to our use of your Information and/or data protection, please contact the Data Controller at our registered office address above.
4 INFORMATION COLLECTED
4.1 You may send us or we may ask you for the following Information:
- Your full name;
- Your address and postcode; and
- Your contact information (such as your email address, telephone number and mobile telephone number).
When you book an appointment, we will ask you to fill out a welcome form which is designed to allow your practitioner to deliver you a better service. The form collects some or all of the following:
- Your full name
- Your contact details (such as your email address, telephone number and mobile telephone number, Skype)
- Date of Birth
- GP details and letter of referral if it is required
- Reason for this booking (brief description)
- What do you hope to gain through therapy?
Therapy Harley Street may also collect certain information about your computer hardware and software, this includes:
- Your IP address;
- Browser type;
- Operating system;
- Access times; and
- Referring website addresses
4.2 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
4.3 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users and to the specific practitioner for the purpose of providing their services.
4.4 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.5 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.6 In addition to the specific purposes for which we may process your personal data, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.7 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
5 HOW YOUR INFORMATION IS USED
5.1 Therapy Harley Street [and/or our partners] may use your Information in the following ways:
To ensure that the content on our Website is presented in the most effective manner for you and your computer;
To provide services that you have requested;
To develop and improve our services;
To contact you to answer any queries you may have.
To contact you for market research or marketing purposes where you have given us permission to do so. For more information on how we may market our services to you please see below.
5.2 Therapy Harley Street may in limited circumstances, disclose your Information to the following third parties:
If Therapy Harley Street is under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply Therapy Harley Street’s terms and conditions and other agreements or protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
6.1 Cookies that we use
Cookies used by our service providers
6.3 Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
7 MARKETING USE
7.1 From time to time, and where you have given your permission to do so, we will contact you with information relating promotions, offers and other information about our services, or our practitioners services.
If you decide you do not want to receive those marketing communications, you can unsubscribe using the following methods:
On each marketing communication there will also be an opportunity for you to unsubscribe.
8 LINKS TO OTHER WEBSITES
9 PROVIDING YOUR PERSONAL DATA TO OTHERS:
9.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Our group of company are www.clustersmedia.co.uk, we use https://secure.acuityscheduling.com for organising appointments and send automatic emails (their GDPR link: https://help.acuityscheduling.com/hc/en-us/articles/360003334751-General-Data-Protection-Regulation-GDPR-)
9.2 We may disclose your personal data to our/our practitioners insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
9.3 We may disclose your personal data to our associates (practitioners) identified at https://www.therapyharleystreet.co.uk/practitioners/ insofar as reasonably necessary for providing our services.
9.4 Financial transactions relating to our website and services are handled by our payment services providers Stripe and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy, https://www.paypal.com/en/webapps/mpp/ua/privacy-full.
9.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
10 OUR RETENTION OF YOUR INFORMATION
10.1 We take all reasonable steps to retain your personal Information only for as long as reasonably necessary. If you no longer want us to store your Information you may request for it to be removed from our records, please see below for details of how to request removal. Please note that such removal may prevent us from supplying certain services to you.
10.2 We will retain your personal data as follows:
Personal data category or categories will be retained for an unlimited period while patients use our services on an ongoing basis.
11 CORRECTING, UPDATING AND REMOVING YOUR INFORMATION
11.1 You have the right to ask us to provide a copy of the Information we hold about you and to have Information removed or any inaccurate Information about you corrected.
11.2 If you would like your Information to be removed from our records or if your Information requires amending, then we will endeavour to correct, update or remove your Information as swiftly as possible. You can request removal by sending an email to email@example.com
11.3 Please note that while we will endeavour to make the updates as promptly as possible, communications may be sent using the original details until the changes have been processed.
12 YOUR RIGHTS:
12.1 We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
12.2 Your principal rights under data protection law are:
(a) The right to access;
(b) The right to rectification;
(c) The right to erasure;
(d) The right to restrict processing;
(e) The right to object to processing;
(f) The right to data portability;
(g) The right to complain to a supervisory authority; and
(h) The right to withdraw consent.
12.3 You have the right to confirmation of whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. As long as the rights and freedoms of others are not affected, we will supply you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can ask for your personal data by email us to firstname.lastname@example.org.
12.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
12.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:
- The personal data is no longer necessary to store in relation to the purposes for which they were collected or otherwise processed.
- You withdraw consent to consent-based processing.
- You object to the processing under certain rules of applicable data protection law.
- The processing is for direct marketing purposes and the personal data has been unlawfully processed.
Please be aware there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
12.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
12.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
12.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
12.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
12.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
12.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.