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Fergus McCausland Health: Privacy Policy (electronic media)
Introduction
Welcome to my privacy policy.
I respect your privacy and am committed to protecting your personal data. This privacy policy will inform you about how I look after your personal data when you visit my website or social media accounts; when you send to or receive emails from my email address and; when you contact me by telephone or other message (regardless of where you make any such connections from). It will also tell you about your privacy rights and how the law protects you. When I refer to ‘website’ in this policy the term will be deemed to include my website, all of my social media accounts or online communities that I utilise from time to time and, communications to or from my email address or systems using my telephone number for example but not limited to Whatsapp, Telegram, text message and the UKIHCA messaging system.
It contains important information on who I am and how and I collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact me or supervisory authorities in the event you have a complaint.
I collect, use and am responsible for certain personal information about you. When I do so I am subject to data protection laws which apply across the European Union and the United Kingdom and I am responsible as ‘controller’ of that personal information for the purposes of those laws.
1. By providing me with your data, you warrant to me that you are over 13 years of age. Important information and who I am
Purpose of this privacy policy
This privacy policy aims to give you information on how I collect and process your personal data through your use of my website, including any data you may provide through this website for example when you fill in any kind of on line form or make contact with me through it.
This website is not intended for children and I do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy policy supplements the other policies and notices and is not intended to override them.
Controller
Fergus McCausland (referred to as “I”, “me”), is the controller and responsible for your personal data in this privacy policy).
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If you have any questions about this privacy policy or my privacy practices or have any requests to exercise your legal rights, please contact me using the details set out below.
Contact details
Fergus McCausland trading as Fergus McCausland Health.
Email address: active-ease@pm.me.
Telephone: 07986 950691 (includes Telegram and Whatsapp)
Postal address: C/O, DoES Liverpool CIC 1st Floor, The Tapestry, 68-76 Kempston Street, Liverpool, Merseyside, United Kingdom. L3 8HL.
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). However, I care deeply about your data protection rights and I would appreciate the chance to deal with your concerns before you approach the ICO so please contact me using the details above in the first instance.
Your duty to inform me of changes
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
Third-party links
2. 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. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy or notice of every website you visit. The data I may 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).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:
∙ Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender. ∙ Contact Data includes billing address, delivery or postal address, email address and telephone numbers. ∙ Financial Data includes bank account and payment card details.
∙ Transaction Data includes details about payments to and from you and other details of products and services you have purchased from me.
∙ Technical Data includes internet protocol (IP) address, your log-in 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.
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∙ 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 my website, products and services.
∙ Marketing and Communications Data includes your preferences in receiving marketing from me and any of my third parties and your communication preferences.
I 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, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
Sensitive Data
Sensitive data refers to data that 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, and criminal convictions and offences. I do not collect any sensitive data about you through my website.
I do not collect any sensitive data about you through the website nor via any of the means of communication with me that I provide. Neither do I request such information. It may be that I reasonably consider that it could be of benefit specifically to an individual client that I request such information. In such a circumstance I will obtain specific consent from the client to both requesting and processing such data.
3. I require your explicit consent for processing any sensitive data. How is your personal data collected? I use different methods to collect data from and about you including through:
∙ Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you (where applicable):
∙ apply for my products or services;
∙ create an account on my website;
∙ subscribe to my service or publications;
∙ request marketing to be sent to you;
∙ enter a competition, promotion or survey; or
∙ give me some feedback or contact me.
∙ Automated technologies or interactions. As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies and other similar technologies. Please see my cookie policy for more details.
∙ Analytics I may receive technical personal data about you from analytics providers such as Google. 3
4. I may receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal. How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
∙ Where I need to perform the contract I am about to enter into or have entered into with you.
∙ Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
∙ Where I need to comply with a legal or regulatory obligation.
∙ To keep you updated about my products and services where you have consented to this. I shall send this information to you email, text or post. You have the right to withdraw consent to marketing at any time by contacting me. See contact details above.
Purposes for which I will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
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I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. My lawful ground for processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, I may send you marketing communications if (i) you made a purchase or asked for information from me about my goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, I may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from me at any time.
I will however only process your personal data for marketing purposes if at my invitation you request me to do so and until any such time as you opt out of such an arrangement between us.
Promotional offers from me
I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you (I call this marketing).
Third-party marketing
I do not share your personal data with any third parties. 6
Opting out
You can ask me 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 me at any time. See contact details above.
Where you opt out of receiving these marketing messages, this will not apply to my processing of personal data provided to me as a result of a purchase of any of my services, or service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see my cookie policy.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose.
5. Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. However I will only do so if it is required by law and on such occasion fully inform you of about such circumstances. Disclosures of your personal data.
My separate privacy policy for clients receiving my service, is that apart from my use of encrypted secure password protected email, I do not share with third parties, any of a client or former client’s personal health information, feedback or testimonial (such information being distinctive from personal data defined above in this policy) unless separate specific consent is given me to do so or if a client and I agree that release of such information is of benefit to him or her In specific circumstance. I would only do so with the client’s informed consent to this in writing.
In relation to this privacy policy (electronic media) I 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:
∙ External Third Parties such as HMRC and regulators or third parties that are required by law to have a business need to know. I do not otherwise have any business relationship with other third parties; and
∙ Third parties to whom I may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.
6. I require all such third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow any 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. International transfers.
I do not transfer your personal data outside the European Economic Area (EEA) or the UK.
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7. If you would like further information please contact me using the contact details in clause 1 above . Data security
I 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, I limit access to your personal data to those third parties who legally have a business need to know. They are subject to a duty of confidentiality.
8. I 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 I am legally required to do so. Data retention
How long will you use my personal data for?
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements. i may retain your personal data for a longer period in the event of a complaint or if i reasonably believe there is a prospect of litigation in respect to my relationship with you.
To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
By law I have to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
If you are not a customer and have not been a customer, I shall retain your data for 2 years following your last engagement with me.
My separate privacy policy for clients is that if you are a customer or have been a customer, I shall retain your data for 7 years following your last engagement with me. This is for the purpose of continuity of quality service for returning clients and for insurance purposes requiring retention of these records for 6 years.
In some circumstances you can ask me to delete your data: see ‘Request erasure’ below for further information.
9. In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
∙ Request access to your personal data.
∙ Request correction of your personal data.
∙ Request erasure of your personal data.
∙ Object to processing of your personal data.
∙ Request restriction of processing your personal data.
∙ Request transfer of your personal data.
∙ Right to withdraw consent.
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If you wish to exercise any of the rights set out above, please contact me.
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, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.
Changes to this privacy policy