Trichological Clinic Limited (The) ("we" and "us") collects, processes and is responsible for personal data relating to our customers, those interested in our products and others. Our use of personal data is regulated by the General Data Protection Regulation (GDPR) which applies across the European Union. We are responsible as ‘controller’ of that personal data for the purposes of data protection legislation.
We are a limited company with our register address at 54 Green Street, London, W1K 6RU and company number 00616855.
We are registered at the Information Commissioner’s Office (ICO) (www.ico.org.uk) and our registration number is ZA441212. You have the right to make a complaint at any time to the Information ICO.
We would be grateful for the chance to deal with any data protection issues you may have before you approach the ICO so please contact us at [email protected] in the first instance.
This Privacy Notice and Policy applies to all processing of customer and potential customer’s personal data.
If viewing this policy online, the policy is supplemental to the Philip Kingsley Products Limited Privacy Policy.
WHAT PERSONAL DATA DO WE COLLECT AND USE?
Collected by us from you and your use of our products and services, in store and online:
Identity Data, includes your name, username or similar identifier.
Contact Data, includes billing and delivery address, email address and telephone numbers.
Transaction Data, includes details about payments, what you have purchased from us and payment card details if provided.
Profile Data, includes username and password, purchases or orders made by you, your interests, preferences, feedback, communications you’ve sent to us or we’ve sent to you.
Marketing and Communications Data, includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Medical Data, includes details of your general health, current medication, family history, number of children, allergies. This data is considered Special Category Data under GDPR and is treated with particular care.
WHAT DO WE DO WITH PERSONAL DATA AND OUR LAWFUL BASIS FOR DOING SO
We our use personal data in a lawful way, usually this will be:
To perform a contract we have entered or about to enter in to with you.
Where it is in our (or a third party’s) legitimate interests and your interests do not override that interest.
To comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data. If we do rely on consent then you may withdraw that consent at any time.
|
Activity. |
Data. |
Lawful basis. |
|
First Appointment Cancellation
|
Identity Data Transaction Data |
Perform a contract |
|
New Registered Patient
|
Identity Data Contact Data Medical Data |
Perform a contract |
|
Blood Tests for Drops
|
Identity Data Medical Data |
Perform a contract |
|
Drops Order
|
Identity Data Contact Data Medical Data |
Perform a contract |
|
GP's / Medical Specialists Contact
|
Identity Data Medical Data |
Perform a contract |
|
Telephone Orders
|
Identity Data Contact Data Transaction Data |
Perform a contract |
|
In Person Orders
|
Identity Data Contact Data Transaction Data |
Perform a contract |
|
Logistics Clinic Telephone Orders
|
Identity Data Contact Data
|
Perform a contract |
|
General Enquiries
|
Identity Data Contact Data |
Perform a contract |
|
Professional Partner Contacts Process
|
Identity Data Contact Data |
. |
|
Occasional Telephone Orders Process |
Identity Data Contact Data Financial Data |
Perform a contract |
|
Salon Contacts Process
|
Identity Data Contact Data
|
. |
|
Clinic Newsletter Signup
|
Contact Data, Marketing and Communications Data Profile Data |
Legitimate interest – To promote our products and services to those interested. This is done in compliance with obligations/rights within Electronic Privacy and Communications Regulations and GDPR. When holding this data and marketing to data subject we give consideration to:
|
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 if 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 above. For the most part, we’ll be using your data to fulfil our contract with you.
CHANGE OF PURPOSE
We will usually only use your personal data for the purposes for which we collected it or if that use 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 [email protected]
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.
PROCESSING OF MEDICAL DATA
When processing your Medical Data we do so on the Lawful Basis that such processing is required to enter in to and perform our contract with you.
Medical Data is considered to be Special Category Personal Data by GDPR and we are required to inform you that we consider that we are allowed to process this Special Category Personal Data as it is necessary for medical diagnosis and the provision of health treatment and is pursuant to a contract with a health professional.
When processing your Medical Data this is done under the responsibility of a professional subject to the obligation of professional secrecy under rules established by The Institute of Trichology, The General Medical Council, The Royal Pharmaceutical Society and/or The Nursing and Midwifery Council.
MARKETING
We may use your Identity, Contact, Technical, Usage and Profile Data to help us what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us only if you have requested information from us or purchased goods or services from us, in each case, you have not opted out of receiving that marketing.
Each time we send you a marketing communication we will give you the opportunity to object to this marketing. If you do object we will stop sending you marketing communication and will retain you details to ensure we do not market to you again. You may also object to marketing by contacting [email protected]
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share the data set out below with the following parties
|
Third party |
Data |
Connected Activity |
|
Pathology services |
Identity Data Medical Data
|
Blood Tests for Drops
|
|
GPs |
Identity Data Contact Data Medical Data
|
Blood Tests for Drops GP's / Medical Specialists Contact Telephone Orders
|
|
Pharmacy |
Identity Data Contact Data Medical Data |
Drops Order
|
|
Third Party Doctors |
Identity Data Contact Data Medical Data |
Drops Order
|
|
Third Party Patient Prescription Manager |
Identity Data Contact Data Medical Data |
Drops Order
|
|
Medical specialists |
Identity Data Contact Data Medical Data |
GP's / Medical Specialists Contact Telephone Orders
|
|
Hosted email service |
Identity Data Medical Data |
GP's / Medical Specialists Contact
|
|
PDQ service provider |
Identity Data Contact Data Transaction Data |
Telephone Orders In Person Orders
|
None of these third parties are located in the European Economic Area (EEA) and we do not transfer personal data outside of the EEA.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
DO YOU HAVE TO PROVIDE US WITH YOUR PERSONAL INFORMATION?
The provision of Identity, Contact and Transaction Data is required from you to enable us to process and deliver your order. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
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. 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.
HOW LONG DO WE KEEP YOUR DATA FOR?
We 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.
YOUR RIGHTS
Under data protection laws, in certain circumstances you have rights relating to your personal data as follows:
Request access to your personal data (a "data subject access request"). This allows you to obtain a copy of the personal data we hold about you and to check we are processing it lawfully.
Request correction of personal data that we hold about you. Any inaccurate or incomplete data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Object to processing of your personal data if we are relying on a legitimate interest as you feel the interest 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.
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; we may have processed your information unlawfully; we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for legal reasons.
Request restriction of processing of your personal data. To ask us to suspend the processing of your personal data if: (a) you want us to establish the data's accuracy; (b) our use of the data is unlawful but you do not want us to erase it; (c) 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.
If you wish to exercise any of the rights set out above, please contact us [email protected]
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 30 days. Occasionally it may take us longer than 30 days 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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version came into effect on 25 May 2018.
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.