This policy applies to your use of this website and any products or services provided by Vicki Crane.
I [Vicki Crane] am committed to safeguarding the privacy of website visitors and service users.
This policy applies where I am acting as a data controller with respect to the personal data of website visitors and service users; in other words, where I determine the purposes and means of the processing of that personal data.
This document was created using a template from SEQ Legal ( https://seqlegal.com )
How your personal data is used
In this section, I have set out:
- The general categories of data that I may possess;
- The purposes for which I may process your data; and
- The legal bases of the processing.
I may process data about your use of my website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal bases for this processing is my legitimate interests; namely monitoring and improving my website and services.
I may process your personal information that is provided in the course of your use of my services (“profile data”). The profile data may include your name, address, telephone number, email address, date of birth, current age, occupation, medical and health information, details of an emergency contact and details of your therapy issue(s) and requirements. The legal bases for this processing is consent and/or the performance of a contract between you and I and/or taking steps, at your request, to enter into such a contract.
I may process information that you post for publication on my website or through my services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering my website and services. The legal bases for this processing is consent.
I may process information contained in any enquiry you submit to me regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
I may process information relating to transactions, including purchases of goods and services, that you enter into with me and/or through my 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 goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and I and/or taking steps, at your request, to enter into such a contract and my legitimate interests, namely the proper administration of my website and business.
I may process information contained in or relating to any communication that you send to me (“correspondence data”). The correspondence data may include the communication content and meta data associated with the communication. My website will generate the metadata associated with communications made using the website contact and/or information forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is my legitimate interests, namely the proper administration of my website and business and communications with users.
I 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 my legitimate interests, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.
I 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 my legitimate interests, namely the proper protection of my business against risks.
In addition to the specific purposes for which I may process your personal data set out in this section, I may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to me, unless I prompt you to do so.
Providing your personal data to others
I may disclose your personal data to my insurers, professional advisers and/or professional body 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 out-of-court procedure.
I may disclose your personal data to appropriate healthcare professionals insofar as reasonably necessary for the purposes of ensuring your safety, obtaining advice, referring you to an appropriate healthcare professional and/or providing you with the highest levels of service.
Financial transactions relating to my website and services are handled by my payment services provider PayPal. I will share transaction data with my payment services provider 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://www.paypal.com/uk/webapps/mpp/ua/privacy-full
In addition to the specific disclosures of personal data set out in this section, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person. I 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.
International Transfers of Your personal data
In this section, I provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
I have offices in the United Kingdom (“the UK”). The European Commission has made an “adequacy decision” with respect to the data protection laws of the UK.
The hosting facilities for my website are situated in the UK.
You acknowledge that personal data you submit for publication through my website and/or services may be available, via the internet, around the world. I cannot prevent the use (or misuse) or such personal data by others.
Retaining & Deleting Personal Data
This section sets out my data retention policies and procedure, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.
Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
I will retain your personal data as follows:
- Personal data category or categories will be retained for a minimum period of 5 years following your first contact with me, and for a maximum period of 10 years following the termination of your therapy and/or services with me.
In some cases it is not possible for me to specify in advance the periods for which your personal data will be retained. In such cases, I will determine the period of retention based on the following criteria:
- The period of retention of personal data will be determined based on the complexity of your therapy case, your enquiry and/or your use of my products and/or services.
Not withstanding the other provisions of this section, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
I may update this policy from time to time by publishing a new version on my website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
In this section, I 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 these summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to confirmation as to whether or not I process your personal data and, where I 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. Providing the rights and freedoms of others are not affected, I will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies will be subject to a reasonable fee.
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.
In some circumstances you have the right to erasure of your personal data without undue delay. Those circumstances include:
- 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 have been unlawfully processed.
However, 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 the the establishment, exercise or defence of legal claims.
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 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, I may continue to store your personal data. However, I 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.
You have the right to object to my 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: performance of a task carried out in the public interest or in the exercise of any official authority invested in me; or the purposes of the legitimate interests pursued by me or a third party. If you make such an objection, I will cease to process the personal information unless I 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.
You have the right to object to my processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, I will cease to process your personal data for this purpose.
You have the right to object to my 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.
To the extent that the legal basis for my processing of your personal data is: consent; or 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 me 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.
If you consider that my 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.
To the extent that the legal basis for my 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. However, you should be aware that withdrawal of consent may affect my ability to provide you with the products and/or services requested by you.
You may exercise any of your rights in relation to your personal data by written notice to me.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that I use
Most web 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:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome)
- https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US (Firefox)
- http://www.opera.com/help/tutorials/security/cookies/ (Opera)
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
- https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari)
- https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd (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 my website.
This website is owned and operated by Vicki Crane.
My principal place of business is at: The Tower Clinic, 8 Tinshill Lane, Cookridge, Leeds LS16 7AP.
You can contact me:
- By post, to the address given above
- By using my website contact form
- By telephone, on the contact number published on my website from time to time
- By email, using the email address published on my website from time to time
Data Protection Officer
The data protection officer is Vicki Crane and the details are listed in the ‘My Details’ section above.