Harley Academy LTD (the Company) are committed to protecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and stored by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting or using www.harleyacademy.com or www.gildclinic.com (the Site) you are deemed to have accepted and consented to the practices described in this policy.
The Site is owned and operated by Harley Academy Ltd (09426500) with registered address 5th floor, 4-6 Copthall Ave, London, EC2R 7DA. Harley Academy Ltd is the Data Controller with ICO registration number ZA227791 expiring on 16/01/2019 and has a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at firstname.lastname@example.org.
INFORMATION WE COLLECT FROM 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). 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.
We collect and process the following data about you:
Information you give us
You may give us information about you by filling in forms on the Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to our marketing database, subscribe to our services, search for a product or service, place an order on our site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, and when you report a problem with the Site.
The information you may give us includes: your username, your password, your last and first name, your company name, address, email address or login details, phone number, date of birth, country and financial information, as well as your, biometric data, family information and medical history.
We rely upon your express opt-in consent to use and process the data described above and your implied consent to comply with our legal obligations where appropriate.
Information we collect about you
With regard to each of your visits to the Site we automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types, languages and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
This data is necessary for us to fulfill legitimate interests, and we rely on this as a lawful basis to use and process the data described above.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
-Strictly necessary cookies. These are cookies that are required for the operation of the Site. They include, by way of general example, cookies that enable you to log into secure areas of the Site, use a shopping cart or make use of e-billing services.
-Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works by, for example, ensuring that users are finding what they are looking for easily.
-Functionality cookies. These are used to recognise you when you return to the Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your region).
Before any cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site.
You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.
Except for essential cookies, all cookies will expire after 12 months.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
Information you give to us
We use this information:
- To administer and manage your account and to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- To respond to communications from you and to provide you with information about other services we offer that are similar to those that you have already enquired about;
- With your express permission and/or where permitted by law, to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable Data Protection Laws (meaning, unless and until it is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and (ii) any successor legislation to the GDPR or the Data Protection Act 1998). If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing;
- To notify you about changes to our services;
- To ensure that content from the Site is presented in the most effective manner for you and for your computer.
Information we collect about you
We will use this information:
- To improve our product and service offerings on our Site;
- To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve the Site to ensure that content is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
As part of our efforts to keep the Site safe and secure;
- To invoice you;
- To make suggestions and recommendations to you and other users of the Site about goods or services that may interest you or them;
- To comply with our legal obligations towards you.
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, sex life, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following basis applies:
- You have given your clear consent to the processing of your personal data for a specific purpose;
- Processing is necessary for the performance of a contract to which you are a party (or are about to be a party);
- Processing is necessary for our compliance with the law;
- Processing is necessary to protect somebody’s life;
- Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law; and/or
- Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests.
We will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, where we need to collect the Personal Data arises by law, or under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a contract you have with us but we will notify you if this is the case at the time.
We will always give you the ability to opt-out of receiving emails from us by unsubscribing using the links provided in those communications, or at the point of providing your details.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with third parties required for the provision of our services. We may share such information with the following third parties, including but not limited to:
Cliniko, Hubspot for contact and customer management purposes;
WooCommerce, Trello, Join.me, Slack, Firebase for productivity and internal organisation purposes;
Mailchimp, Google G Suite, Hubspot and Amazon Web Services for storage purposes;
Stripe, Worldpay, GoCardless, Receipt Bank, iZettle and Xero for payment and invoicing purposes;
Google Analytics, Facebook, Linkedin for marketing and insight collection purposes
where they require access to your data to supply products and services to you on our behalf, including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, such as in relation to registration, log in/out, payment processing; and Analytics and search engine providers that assist us in the improvement and optimisation of the Site.
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.
We may disclose your personal information to third parties :
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets where it is relevant to the part of the business being transferred and the purchaser shall be permitted to use the data for the purposes for which it was originally collected by us; and
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your enquiries, the processing of your payment details and/or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of EU-approved Model Contractual Arrangements. 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 will notify you and any applicable regulator of a breach where we are legally required to do so.
All information you provide to us is stored on our servers and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use our reasonable endeavours to use procedures and security features to try to prevent unauthorised access including but not limited to the use of antivirus softwares, firewalls, password protection and encryption methods.
HOW LONG WE STORE YOUR PERSONAL DATA
We will only keep this information for as long as is necessary for the performance of the original legitimate purpose for collecting the information.
We are required by law to retain certain personal data for a specific time period. We aim to comply with statutory and regulatory record keeping rules relating to both patients and students taking our examinations. We ought to keep patients records for 7 years after the appointment date and student records for 3 years after their qualification.
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.
We will get your express opt-in consent before we share your personal data with any third parties for marketing purposes. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at email@example.com or by unsubscribing using the links contained in the marketing emails.
The Site may, from time to time, contain links to and from the websites of our partner networks and affiliates or to websites shared by other users. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the right to access information held about you and to ask for a copy of such information. Please contact us for more details at the Company Address.
UNDER THE GDPR, you have the right to:
REQUEST ACCESS deletion or correction to/of the information that we hold about you.
BE INFORMED of what data we hold and the purpose for processing the data as a whole or in parts and ask for a copy of that data.
ERASURE – request to be forgotten (this is not an absolute right) by ourselves and our affiliates
RECTIFICATION – have any information that we hold about you that is incorrect or incomplete be rectified by ourselves and affiliates.
RESTRICT PROCESSING of the information we hold about you (so that inaccuracies may be corrected etc).
OBJECT to the processing of your data.
DATA PORTABILITY – you can obtain and reuse the information that we hold about you.
CHALLENGE any data we use for the purposes of automated decision-making and profiling, in certain circumstances.
COMPLAIN to a supervisory authority.
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.