Welcome to Matt Long Mind and Body (“MLM&B”) privacy notice.
“MLM&B” respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, to include when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 Purpose of this Privacy Notice
This privacy notice aims to give you information on how “MLM&B” collects and processes your personal data, including any data you may provide through on our website.
This website is not intended for children and we do not knowingly collect data relating to children.
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 aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
“MLM&B” is the controller and responsible for your personal data (collectively referred to as “MLM&B””, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
1.3 Contact Details
Our full details are:
Matt Long Mind and Body
DPO: Matt Long
7 Chichester Close
Bury St Edmunds
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.
1.4 Changes to the Privacy Notice and your duty to inform us of changes
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.
1.5 Third-Party Links
Our 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. WHAT DATA DO 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 process certain types of personal data about you as follows:
Identity Data may include your first name, maiden name, last name, marital status, title, date of birth and gender.
Contact Data may include your address, email address and telephone numbers.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences. (e.g. cookie data, clickstream data, browsing history, responses to direct marketing, and opt-outs from direct marketing including internet protocol (IP) address, Facebook details, Pinterest details, Twitter details, Instagram details, 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 our website)
We also collect, use and share Aggregated 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 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.
We need to collect the following sensitive data about you in order to provide you with our treatment services that are safe to perform, to check for medical contra-indications, to enable us to provide treatments tailored to your health requirements and meet the requirements of our professional body (The Institute of Sport and Remedial Massage, ISRM) and for insurance purposes:
Current state of health which will include any medical condition for which you are undergoing diagnosis or help through a medical professional such as a GP or consultant. This also includes details of recent (within 6 weeks of appointment) or forthcoming operations, recent (within 6 weeks of appointment) accidents and injuries.
Medical/health history which will include any historical medical conditions that you have sought help for through a medical professional such as a GP or consultant. This also includes details of historical operations, accidents and injuries.
Medication that has been prescribed by a health professional such as a GP or consultant. This does not include food supplements.
We require your explicit consent for processing sensitive data, so when you submit your details during the client consultation at your first appointment, you will be required to sign and date the client consultation form.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (our treatment services to you). If you don’t provide us with the requested data, we have the right to refuse to provide you with these services but if we do, we will notify you at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through:
Direct interactions: You may provide data by communicating with us during the client consultation from which we will complete a client consultation form for you. But also by:
Ongoing note-taking during and post-treatment;
Giving us feedback;
Automated technologies or interactions. As you interact with our website, Facebook site, Twitter site and Instagram site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies such as pixels.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
analytics providers such as Google and Facebook based outside the EU;
advertising networks such as Facebook etc. based inside OR outside the EU; and
search information providers based inside OR outside the EU; and
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
Identity and Contact Data from publicly available sources such as Linked In, Companies House and the Land Registry
Via client consultation forms completed prior to receiving ‘taster’ treatments at events such as health & well-being events.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
To ascertain how to perform a safe treatment within the limitations of your past or present health or medical conditions. To record the progress and outcome of the
To send out reminders of your booked treatment 24 hours before.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us .
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
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 email us at email@example.com 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 below.
To register you as a new client
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data
(c) Marketing and Communications
Lawful basis for processing
Performance of a contract with you
(a) Effectiveness of massage treatments received by you
(b) Necessary to comply with a legal obligation
(c) Necessary to know how we can make improvements to the services we provide
Necessary for us to develop our products/services and grow our business
You will receive marketing communications from us if you have:
requested information from us or received massage services from us; or
if you provided us with your details when you entered a competition or registered for a promotion or free resources; and
in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of receiving treatment services from us or other transactions.
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 find out more about 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 a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent 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:
We may disclose your personal data to our employees and agents to the extent necessary to provide you with the services you have requested
We may make your personal data available to selected third parties who act on our behalf to support our operations (for example payment services)
Our marketing suppliers and contractors (e.g. Advertising and website) who may need to have access to your personal data to provide support and enable us to provide products and services, subject to appropriate contractual protections in accordance with applicable law.
To the extent necessary to establish, exercise or defend legal rights or claims, or for the purposes of investigating actual or suspected unlawful activity
Professional insurers who provide insurance services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. 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 take the security of our clients’ data very seriously and we use appropriate measures to protect all personal information collected in a secure, controlled environment consistent with GDPR legislation. The personal data that we collect from you is stored on UK based servers. Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. When you submit your personal information through our websites this is at your own risk.
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.
7. DATA RETENTION
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.
By law, we have to keep basic information about our clients (including Contact and Identity Data) for six years after they cease being customers for tax purposes. However, it is an obligation to our insurers and professional body (ISRM) that we retain all personal data including Contact, Identity and Sensitive Data for a minimum of seven years from the date of the last treatment provided by us.
In some circumstances you can ask us to delete your data however if the client is under continued care of ML Mind and Body, this may adversely affect the treatments and also contravene our professional requirements so under these circumstances we may have to discontinue your treatments.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under Subject to applicable law, you may have the following rights in relation to your personal data:
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.
The right to lodge a complaint with a supervisory authority (The Information Commissioner’s Office).
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.
The right to request access to, or copies of, your personal data that we process.
The right to request correction of any inaccuracies in your personal data.
The right to object, on legitimate grounds, to the processing of your personal data.
The right to request that your personal data are deleted. This does not affect your statutory rights. If you wish to exercise any of these rights, please contact us as described in the section below headed ‘Contact’. We may also need to ask you for further information to verify your identity before we can respond to any request.
If you wish to exercise any of the rights set out above, please contact us.
8.1 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.
8.2 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.
8.3. 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.
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.
CHANGE TO PRIVATE POLICY
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
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