1. Who we are
Giraffe Healthcare CIC is a community interest company registered under the Companies Acts (company number SC595189) and has its registered office at c/o Glasgow Caledonian University, Cowcaddens Road, Glasgow, G4 0AB (“we”, “our”).
For the purpose of the General Data Protection Regulation (“GDPR”), we are the Data Controller of any personal data we collect from you via this website, http://www.giraffehealth.com (“website”) or otherwise (including by telephone, email, post or face to face).
We respect your privacy and are committed to protecting your personal data. We adhere to the principles of the GDPR when processing your personal data.
This privacy notice (together with our terms and conditions and any other documents referred to within it) outlines how we collect and process your personal data through your interaction with the website or that you provide to us and how the law protects you. Please read this privacy notice so that you are aware of how and why we are using your personal data.
If you have: (i) any concerns about our processing of your personal data; or (ii), you have a general enquiry in relation to data protection, please contact firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK’s supervisory authority for data protection issues (www.ico.gov.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. What is personal data?
Personal Data: means any information relating to an identified or identifiable natural person (“Data Subject”) from which that Data Subject can be identified directly or indirectly (in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
Special Category of Data: means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
When we refer to “personal data”, we mean both personal and special category of data.
3. The data we collect about you
We primarily collect personal data from you through your direct interactions with us by email, telephone or face to face.
We may collect the following personal data to undertake one of the services that you have requested:
- Email address;
- Health data including details of the primary diagnosis of any neurological, cardiovascular, respiratory, orthopaedic or rheumatological conditions;
- Your username and password;
- Any data regarding how you use the website through cookies that we use on the website;
- IP addresses - we may collect information (where available) about your IP (internet protocol) address, operating system and browser type. This data provides us with information about your browsing actions and patterns. It is used to inform improvements to the website and for internal system administration; and
- Any other information you post, e-mail or otherwise send to us.
4. Where will we store your data?
Your personal data will be stored in the UK.
5. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, 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 product or service you have with us but we will notify you if this is the case at the time.
6. How we use your personal data
To provide our services to you, we need to know your name, contact details and medical diagnosis.
We will only use your personal data when the law allows us to. Most commonly, we will use our personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into, or have entered into, with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests are fundamental rights do not overrise those interests;
- Where we need to comply with a legal obligation; and
- For office administration and internal record keeping purposes.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
7. Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where appropriate).
We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than on basis has been set out in the table below:
|What we use your data for:||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client.||
|Performance of a contract with you.|
|To process and deliver our web based physio services.||
|Performance of a contract with you.|
To manage our relationship with you, which will include:
(a) notifying you about changes to the website terms or privacy notice; and
(b) asking you to leave a review or take a survey.
(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation; and
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our web based physio services).
|To respond to an enquiry made through the website||Email address.||It is in our legitimate interest to provide you with information regarding our services, and to provide an efficient service to you as a potential or existing client.|
|Cookies through the website||Technical data regarding your equipment, browsing actions and patterns.||We ask you to provide consent for all non-essential cookies that we use on the website.|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason 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.
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.
8. Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transaction.
9. Disclosure of your personal data
We may disclose your personal data 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 we or substantially all of our assets are acquired by a third party, in which case, personal data held by us about you will be one of the transferred assets;
- to protect the rights, property, or safety of us or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In all instances where we disclose your personal data to third parties, we will ensure that your data is appropriately protected.
Where our suppliers process our personal data on our behalf, we require them to put in place appropriate security measures to protect your personal data in line with our policies. We do not allow our suppliers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, in accordance with our instructions and data protection law.
10. International Transfers
We do not transfer your personal data outside the European Economic Area (the “EEA”).
11. Is your personal data safe?
We work hard to protect your personal data and have adopted appropriate technical and organisational measures to prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or destroyed.
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 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.
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 personal data transmitted to us via the internet. Any transmission is at your own risk.
12. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for (including, for the purposes of satisfying any legal, regulatory or reporting requirements). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
Cookies are small text files that are stored on your computer or mobile device when you visit the website.
14. Your Legal Rights
Under certain circumstances, you have rights under data protection law in relation to your personal data. We have summarised your rights below:
- You can request access to your personal data;
- You can seek to restrict our processing of your personal data or ask us to rectify any personal data we hold about you;
- You can object to us processing your personal data where we are relying on legitimate interest and we will cease processing for the purpose you object to. An exception to this would be where we have compelling legitimate grounds for processing which override your interests, rights and freedoms or where it is necessary for the establishment, exercise or defence of legal claims. You can also object or withdraw your consent to marketing at any time and we will stop immediately;
- You have the right to ask us to provide you with your personal data in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party. More information can be found at www.ico.org.uk;
- You have a right to ask for the data held about you to be corrected. Please help us keep our records updated by informing us of any changes to your personal data; and
- You have the right to ask us to erase the personal data we hold about you. Such circumstances include: (a) where we no longer need your personal data for the purposes set out above; (b) if you withdraw your consent to our processing; (c) if you object to our processing based on our legitimate interest and we have no overriding legitimate grounds to continue processing your personal data; (d) if we process the data unlawfully; or (e) where the personal data has to be erased to comply with legal obligation to which we are subject. We will consider any such request in line with data protection law. Please note this is not an absolute right and there may be circumstances where we choose not to delete all of the personal data we hold about you. More information about your right of erasure can be found at www.ico.org.uk.
If you would like to exercise any of the rights set out above, please contact email@example.com.
15. Third Party Links
16. Changes to our Privacy Notice
We keep this privacy notice under regular review. Any changes we may make to our privacy notice in the future will be posted on the website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org.