PRIVACY POLICY
Lynton Clinics Ltd is committed to protecting your privacy and will ensure that any information you provide to us will be collected and used in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. We will not share your data with any third party except for administrative purposes relating to the services we provide and where we may be required to do so by law.
INTRODUCTION
This privacy notice explains how Lynton Clinics Ltd uses your personal data when we are providing a service to you or you are visiting our website and your legal rights in respect of our use of your data. It applies to our clients and prospective clients.
Applicable data protection legislation includes (but may not be limited to) the General Data Protection Regulation (Regulation (EU) 2016/679) (i.e., the “GDPR”), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulation 2003.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully informed of how and why we are using your data.
1. IMPORTANT INFORMATION – AND WHO WE ARE
Data Controller
Lynton Clinics Ltd is the data controller and is responsible for your personal data (collectively referred to as Lynton Clinics Ltd., “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Full name of legal entity: Lynton Clinics Ltd., t/a The Lynton Clinic
Email address: thelyntonclinic@lynton.co.uk
Postal address: Unit 9D, Holmes Chapel Business Centre, Manor Lane, Crewe, Cheshire, CW4 8AF
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.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.
Changes to the Privacy Notice and Your Duty to Inform Us of Changes
This version was last updated in February 2021 and historic versions can be obtained by contacting us.
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.
Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. DATA WE COLLECT ABOUT 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).
We may collect, use and retain different categories of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, former names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address, billing address (if relevant), delivery address (if relevant), email address and telephone numbers. We may also ask you for an emergency contact number.
• Financial Data includes bank account, payment card details. If applying for credit this may also include salary, outgoings, ability to pay and credit references.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Treatment Data includes information about the treatment you wish to (or have) received from us. This information could include ‘health data’ which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected. Depending on your treatment this may also include photographs which form an important part of your treatment record.
We also collect and use aggregated (anonymous) data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
With the exception of treatment data, we do not collect any other special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If You Fail To Provide Personal Data
Where we need to collect personal data by law or under the terms of a contract that 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 (for example, to provide you with goods or services). 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.
The Lynton Clinic website logs IP addresses and uses tracking technology, such as cookies and pixels, to provide a more fluid user experience and allow us to better understand how visitors use our website. See section 4 below.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use a number of different channels to collect your personal data. These include:
Direct interactions with you. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• order or make an enquiry regarding any of our products or services, either online, over the phone or in our clinic;
• from your healthcare practitioner if they refer you to us;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or complete a survey;
• give us some feedback or post on one of our social media accounts.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to and in accordance with this privacy notice. Most commonly, we will use your personal data in the following circumstances:
• where we need to perform the contract that we are about to enter into or have entered into with you for the provision of a product or service;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation;
• marketing Activities; and
• to respond to any complaint and help us to establish, exercise or defend legal claims.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message and the use of non-essential cookies and similar tracking technologies. You have the right to withdraw consent to marketing at any time by contacting us.
Using Your Health Data
In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.
Purposes for Which We May Use Your Personal Data and Our Legal Basis
We have set out below, in a table format, a description of all the ways we may 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. Note that 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 require further details about the specific legal basis that we are relying on to process your personal data where more than one basis has been set out in the table below.
| Purpose/Activity |
Type of Data |
Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer |
(a) Identity
(b) Contact
|
Performance of a contract with you |
|
To process and deliver our services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Send appointment reminders by email and SMS
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Health information
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (e.g., to recover debts due to us)
(c) Necessary for us to provide health care or treatment
|
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Health information |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Necessary for us to provide health care or treatment
|
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Consent |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|
(a) Technical
(b) Usage
|
Consent |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
|
Consent |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can choose the channel by which you will receive marketing and change your preferences at any time.
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.You will only receive marketing communications from us if you have requested information from us or specifically opted-in to receive marketing by email. We may send marketing by SMS, post or call you by telephone, where permitted to do so by law.
Third-Party Marketing
We will never sell or disclose your data to a third party for the purpose of marketing. We may promote third party products or services on behalf of another organisation but will only do so where we have your explicit consent.
Opting Out
You can ask us or to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out from receiving marketing messages, this will not apply to other communications, for example appointment reminders.
Cookies & Web Tracking
How we use cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Analytics cookies
We use Google Analytics to collect information on how visitors use of our website. This information helps us to generate reports and to help us develop our website. These cookies collect information in an anonymous form, the information collected is the number of visitors to the site, how visitors have arrived at our website and all the pages that are visited. For further information, you can visit http://www.google.com/policies/privacy/
Further information on cookies
If you’d like to learn more about cookies in general and how to manage them, visit aboutcookies.org
If you’d like to opt out of cookies, please go to the Network Advertising Initiative website
Please note that we’re not responsible for the content of external websites.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Change of Purpose
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Such third parties consist of:
• IT: Service providers acting as processors who provide IT and system administration services.
• Advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. 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. 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.
8. DATA RETENTION
How Long Will You Use My Personal Data For?
Lynton Clinics Ltd 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights are as follows:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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 one month. Occasionally it may take us longer than a month 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.
10. GLOSSARY
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Necessary for us to provide health care or treatment means processing your special categories of personal data (i.e., health data) where it is necessary for the purposes of preventive or occupational medicine, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or UK law or pursuant to contract with a health professional (subject to required conditions and safeguards).
