Website Privacy notice

We are Healthstart Trading Ltd t/a Bo’ness Spinal Health Center.
We’re a company registered in Scotland with company numberSC651729, whose registered address is at 1 Market Street, Bo’ness, Falkirk, EH519AD. In this
privacy notice we will refer to ourselves as ‘we’, ‘ us’ or ‘our’.

You can get hold of us in any of the following ways:

(a) by phoning us on 01506828828;

by e-mailing us at info@bonessspinalhealth.co.uk; or

(b) by writing to us at 1 Market Street, Bo’ness, EH519AD.

We take the privacy, including the security, of personal information we
hold about you seriously. This privacy notice is designed to inform you
about how we collect personal information about you and how we use that
personal information. You should read this privacy notice carefully so that
you know and can understand why and how we use the personal information we
collect and hold about you.

We do not have a Data Protection Officer, but if you have any questions
about this privacy notice or issues arising from it then you should contact
Dr Melinda Warren, who is responsible for matters relating to data
protection at our organisation, including any matters in this privacy
notice. You can contact her using the details set out above.

We may issue you with other privacy notices from time to time, including
when we collect personal information from you. This privacy notice is
intended to supplement these and does not override them.

We may update this privacy notice from time to time. This version was last
updated on September 27, 2022.

1. Key Definitions

The key terms that we use throughout this privacy notice are defined below,
for ease:
Data Controller
: under UK data protection law, this is the organisation or person
responsible for deciding how personal information is collected and stored
and how it is used.

Data Processor
: a Data Controller may appoint another organisation or person to carry out
certain tasks in relation to the personal information on behalf of, and on
the written instructions of, the Data Controller. (This might be the
hosting of a site containing personal data, for example, or providing an
email marketing service that facilitates mass distribution of marketing
material to a Data Controller’s customer-base.)

Personal Information:
in this privacy notice we refer to your personal data as ‘personal
information’. ‘Personal information’ means any information from which a
living individual can be identified. It does not apply to information which
has been anonymised.

Special Information
– certain very sensitive personal information requires extra protection
under data protection law. Sensitive data includes information relating to
health, racial and ethnic origin, political opinions, religious and similar
beliefs, trade union membership, sex life and sexual orientation, and
includes genetic and biometric information.

2. Details of personal information which we collect and hold about you

2.1 Set out below are the general categories and details of retention
periods in relation to those categories (see section 8 below for more
details about retention) and in each case the types of personal information
which we collect, use and hold about you:

2.2 The types of personal data we collect about you may differ from person
to person, depending on who you are and the relationship between us.

3. Details of special information which we collect and hold about you

3.1 Special information is explained in section 1 above. We do not collect
or hold any special information about you, including

(a) race;

(b) ethnic origin;

(c) politics;

(d) religion;

(e) trade union membership;

(f) genetics;

(g) biometrics;

(h) health;

(i) sex life;

(j) sexual orientation.

3.2 Where we do hold special information about you then our retention
periods are as for Identity Information above.

3.3 We do not collect information from you relating to criminal convictions
or offences.

4. Details of how and why we use personal information

4.1 We are only able to use your personal information for certain legal
reasons set out in data protection law. There are legal reasons under data
protection law other than those listed below, but in most cases, we will
use your personal information for the following legal reasons:

(a) Contract Reason: this is in order to perform our
obligations to you under a contract we have entered into with you;

(b) Legitimate Interests Reason: this is where the use of
your personal information is necessary for our (or a third party’s)
legitimate interests, so long as that legitimate interest does not override
your fundamental rights, freedoms or interests.

(c) Legal Obligation Reason: this is where we have to use
your personal information to perform a legal obligation by which we are
bound; and

(d) Consent Reason: this is where you have given us your
consent to use your personal information for a specific reason or specific
reasons.

4.2 [As explained in section 3 above, there are more sensitive types of
personal data which require higher levels of protection. Where we process
such sensitive types of personal data we will usually do this in the
following circumstances:

(a) We have your explicit consent;

(b) Where it is necessary in relation to legal claims;

(c) Where you have made the personal data public

4.3 So that we are able to provide you with goods and services, we will
need your personal information. If you do not provide us with the required
personal information, we may be prevented from supplying the goods and
services to you.

4.4 It is important that you keep your personal information up to date. If
any of your personal information changes, please contact us as soon as
possible to let us know. If you do not do this then we may be prevented
from supplying the goods and services to you (for example, if you change
your number and do not tell us, then we may be unable to contact you about
appointments).

4.5 Where we rely on consent for a specific purpose as the legal reason
for processing your personal information, you have the right under data
protection law to withdraw your consent at any time. If you do wish to
withdraw your consent, please contact us using the details set out at
the beginning of this notice. If we receive a request from you
withdrawing your consent to a specific purpose, we will stop processing
your personal information for that purpose, unless we have another
legal reason for processing your personal information, in which case,
we will confirm that reason to you.

4.6 We have explained below the different purposes for which we use your
personal information and, in each case, the legal reason(s) allowing us to
use your personal information. Please also note the following:

(a) if we use the Legitimate Interests Reason as the legal reason for which
we can use your personal information, we have also explained what that
legitimate interest is; and

(b) for some of the purposes we may have listed more than one legal reason
on which we can use your personal information, because the legal reason may
be different in different circumstances. If you need confirmation of the
specific legal reason that we are relying on to use your personal data for
that purpose, please contact us using the contact details set out at the
start of this privacy notice.

4.7 Sometimes we may anonymise personal information so that you can no
longer be identified from it and use this for our own purposes. In
addition, sometimes we may use some of your personal information together
with other people’s personal information to give us statistical information
for our own purposes. Because this is grouped together wither other
personal information and you are not identifiable from that combined data
we are able to use this.

4.8 Under data protection laws we can only use your personal information
for the purposes we have told you about, unless we consider that the new
purpose is compatible with the purpose(s) which we told you about. If we
want to use your personal information for a different purpose which we do
not think is compatible with the purpose(s) which we told you about then we
will contact you to explain this and what legal reason is in place to allow
us to do this.

5. Details of how we collect personal information and special information

5.1 We usually collect Identity Information, Contact Information, Payment
Information, Transaction Information, Survey Information, Marketing
Information, Device Information, and Imaging Information directly from you
when you[fill out a form, survey or questionnaire, purchase goods, services
and/or digital content from us, contact us by e-mail, telephone, in writing
or otherwise. This includes the personal information which you provide to
us when you enter a competition or survey.

5.2 [We may receive some of your personal information from third parties or
publicly available sources. This includes:

(a) Contact Information and Payment Information from our selected
third-party suppliers, such as private health insurance companies;

(b) Identity Information and Contact Information from selected data brokers
(not currently applicable);

(c) Identity Information and Contact Information from publicly available
sources such as Companies House;

(d) Website, Device and Technical Information from third parties such as
analytics providers like Google;

(e) Any other methods by which we choose to collect personal data;

5.3 We may also receive Website, Device and Technical Information
automatically from technologies such as cookies which are installed on our
website. To find out more about these please see our cookie policy which is
available on our website.

6. Details about who personal Information may be shared with

6.1 We may need to share your personal information with other organisations
or people. These organisations include:

(a) Other companies in our group (who may might act as joint data
controllers or as data processors on our behalf) and who provide IT
services which require them to have access to personal information.

(b) Third parties who are not part of our group. These may include:

(i) Suppliers: such as IT support services, payment providers,
administration providers, and marketing agencies who are based in the UK;

(ii) Government bodies and regulatory bodies: such as HMRC, fraud
prevention agencies etc who are based in the UK;

(iii) Our advisors: such as lawyers, accountants, auditors, and insurance
companies who are based in the UK;

(iv) Our bankers who are based in the UK;

(v) E-mail platforms who are based in the UK;

(c) any organisations which propose to purchase our business and assets in
which case we may disclose your personal information to the potential
purchaser.

6.2 Depending on the circumstances, the organisations or people who we
share your personal information with will be acting as either Data
Processors or Data Controllers. Where we share your personal information
with a Data Processor we will ensure that we have in place contracts, which
set out the responsibilities and obligations of us and them, including in
respect of security of personal information.

6.3 We do not sell or trade any of the personal information which you have
provided to us.

7. Details about transfers to countries outside of the EEA

7.1 We do not transfer your personal information outside of the EEA.

8. Details about how long we will hold your personal information

8.1 We will only hold your personal data for as long as is necessary. How
long is necessary will depend upon the purposes for which we collected the
personal information (see section 4 above) and whether we are under any
legal obligation to keep the personal information (such as in relation to
health, accounting or auditing records or for tax reasons). We may also
need to keep personal information in case of any legal claims.

We have set out above the details of our retention periods for different
types of data. You can find them in in section 2.

9. Automated decision making

9.1 ‘Automated decision making’ is where a decision is automatically made
without any human involvement. Under data protection laws, this includes
profiling. ‘Profiling’ is the automated processing of personal data to
evaluate or analyse certain personal aspects of a person (such as their
behaviour, characteristics, interests and preferences).

9.2 Data protection laws place restrictions upon us if we carry out
automated decision making (including profiling) which produces a legal
effect or similarly significant effect on you.

9.3 We do not carry out automated decision making (including profiling)
which produces a legal effect or similarly significant effect on you. If we
do decide to do this then we will notify you and we will inform you of the
legal reason we are able to do this.

10. your rights under data protection law

10.1 Under data protection laws you have certain rights in relation to
your personal information, as follows:

(a) Right to request access: (this is often called
‘subject access’). This is the right to obtain from us a copy of the
personal information which we hold about you. We must also provide you with
certain other information in response to these requests to help you
understand how your personal information is being used.

(b) Right to correction: this is the right to request that
any incorrect personal data be corrected, and that any incomplete personal
data is completed.

(c) Right to erasure: (this is often called the “right to
be forgotten”). This right only applies in certain
circumstances. Where it does apply, you have the right to request us to
erase all your personal information.

(d) Right to restrict processing: this right only applies
in certain circumstances. Where it does apply, you have the right to
request us to restrict the processing of your personal information.

(e) Right to data portability: this right allows you to
request us to transfer your personal information to someone else.

(f) Right to object: you have the right to object to us
processing your personal information for direct marketing purposes. You
also have the right to object to us processing personal information where
our legal reason for doing so is the Legitimate Interests Reason (see
section 4 above) and there is something about your particular situation
which means that you want to object to us processing your personal
information. In certain circumstances you have the right to object to
processing where such processing consists of profiling (including profiling
for direct marketing).

10.2 In addition to the rights set out in section 10.1, where we rely on
consent as the legal reason for using your personal information, you have
the right to withdraw your consent. Further details about this are set out
in section 4.5.

10.3 If you want to exercise any of the above rights in relation to your
personal information, please contact us using the details set out at the
beginning of this notice. If you wish to make a request, please note:

(a) we may need certain information from you so that we can verify your
identity;

(b) we do not charge a fee for exercising your rights unless your request
is unfounded or excessive; and

(c) if your request is unfounded or excessive then we may refuse to deal
with your request.

11. Marketing

11.1 You may receive marketing from us about similar goods and services,
where either you have consented to this, or we have another legal reason by
which we can contact you for marketing purposes.

11.2 However, we will give you the opportunity to manage how or if we
market to you. In any e-mail which we send to you, we provide a link to
either unsubscribe or opt-out, or to change your marketing preferences. You
can also request that we do not contact you in person at clinic reception.
To change your marketing preferences, and/or to request that we stop
processing your personal information for marketing purposes, you can always
contact us on the details set out at the beginning of this notice.

11.3 If you do request that we stop marketing to you, this will not prevent
us from sending communications to you which are not to do with marketing
(for example in relation to future appointments which you have made with
us) .

11.4 We do not pass your personal information on to any third parties for
marketing purposes.

12. Complaints

If you are unhappy about the way that we have handled or used your personal
information, you have the right to complain to the UK supervisory authority
for data protection, which is the Information Commissioner’s Office ( ICO). Please do contact us in the first instance if you
wish to raise any queries or make a complaint in respect of our handling or
use of your personal information, so that we have the opportunity to
discuss this with you and to take steps to resolve the position. You can
contact us using the details set out at the beginning of this privacy
notice.

13. Third Party Websites

Our website contains links to third party websites in our group who
contribute to promoting and growing our business.