Privacy Policy

PRIVACY POLICY

Introduction

This Privacy Policy describes how and when we collect, use, and share information when you attend an appointment, attend an event, purchase a product from us, contact us, or otherwise use our services. It also details the rights you have over your personal data and how you can exercise those rights.  This is to comply with the General Data Protection Regulations (GDPR) 2018.

Emerald Phoenix is committed to maintaining the confidence and trust of visitors to our site, users of our services and participants at our events. Our ethos is to securely store the minimum amount of personal data necessary to run our website and business.

From time to time we may need to amend this policy and will publish the updated version on our website. You should check our Terms and Conditions and Privacy Policies occasionally to ensure you are happy with any changes.

The Information We Collect

When you use our services (treatments, events, sales), you will normally provide us with certain information, such as your name, email address, postal address, medical information and payment information.  We store your information in an electronic database which is fully password protected; and for treatments, a paper diary system which is kept in locked storage when not in use. Other scanned or electronically submitted data are stored in password protected and encrypted systems.

When attending events such as fire-walks you will be required to sign a disclaimer before taking part; this will be stored as per the other information in the paragraph above.

Note that we are not using cookies presently, and will update this policy when this changes.

Why We Need Your Information and How We Use It

We rely on a number of legal bases to collect, use, and share your information, including:

  • where it is necessary for the purposes of the provision of health care as needed to provide our services, such as when we use your information to fulfil your KCR assessment and treatment, or to provide customer support;
  • when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for our mailing list;
  • if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law;

Information sharing and disclosure

Information about our patients/customers is important to our business. We may share your personal information for very specific reasons and in limited circumstances, as follows:

  • Medical professionals. With your consent we will share information with medical professionals such as your GP or consultant to allow continuity of care.
  • Service providers. We engage certain trusted third parties to perform functions and provide services to our business, such as external reception services. We will share your personal information with these third parties, but only to the extent necessary to perform these services.
  • Business transfers. If we sell or merge our business, we may disclose your information as part of that transaction, only to the extent permitted by law and with your consent.
  • Compliance with laws. We may collect, use, retain, and share your information if we are legally required to.

Data Retention

We retain your personal information only for as long as necessary to provide you with our services and as described our Privacy Policy. However, we may also be required to 0retain this information to comply with my legal and regulatory obligations, to resolve disputes, and to enforce my agreements. The retention of medical records is normally a minimum of 8 years, after the last appointment.  For customers who are not patients but may have bought products from our business we will keep any data you may have provided for a minimum of 6 years in line with tax legislation.

Payment and booking details

We use iZettle to process purchases made by card.  We do not have access to any of your card or PIN information. We keep records of payments made to us by you to comply with tax legislation.

iZettle have complied with GDPR  legislation. Their privacy policy can be found here.

We use PayPal to process purchases made online.  We do not have access to any of your card or PIN information. We keep records of payments made to us by you to comply with tax legislation.

Paypal have complied with GDPR  legislation. Their privacy policy can be found here.

We use Events Frame to manage event ticketing. EventsFrame’s processes and platform have been built to be GDPR compliant. Their privacy policy can be found here.

Transfers of Personal Information Outside the EU

We may store and process your information through third-party hosting services in the US and other jurisdictions. As a result, we may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. If we are deemed to transfer information about you outside of the EU, we rely on Privacy Shield as the legal basis for the transfer, as X Cloud is Privacy Shield certified.

Social Media

We interact with the public using Facebook. Anyone posting material to our website, and social media pages and feeds is doing so publicly and subject to having agreed (consented) with the Privacy Policies and Terms and Conditions of those services. While we do police these for inappropriate content, you are responsible for what you post and the consequences of your actions.

How we protect your information

We protect your information using technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification. While we have employed security technologies and procedures to assist safeguarding your personal information, no system or network can be guaranteed to be 100% secure.

All Our staff are responsible for ensuring that any personal data that they possess is held securely and is not disclosed to any unauthorised third party.

Emerald Phoenix will only retain your information for as long as is reasonably needed for each purpose, subject to your consent, and subject to data retention and processing as may be required by Law.

Your rights

In this section we summarise your rights under GDPR.

You have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below:

  • You have the right to access and receive a copy of the personal information We hold about you by contacting me using the contact information below.
  • Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. In the case of health records these are normally exempt from change and deletion requests.
  • You can object to (i) my processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from me after providing your express consent to receive them. In such cases, We will delete your personal information unless We have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
  • If you wish to raise a concern about my use of your information (and without prejudice to any other rights you may have), you have the right to do so with the Information Commissioner at www.ico.org.

Contact details

For purposes of the GDPR, I, Clara Hill, am the data controller of your personal information. If you have any questions or concerns, you may contact me at

clara@emerald-phoenix.co.uk

Emerald Phoenix, August 2018

 

Updates to policy:
27 August 2018 – added Events Frame ticket management

12 August 2018 – Initial version