Calmblue Holistic Therapies

GENERAL PRIVACY NOTICE

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://calmblue.org.uk including any information you may provide through our site when you purchase a product or service, sign up to our newsletter, or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 13 years of age.

Calmblue Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out.

Contact Details

Our full details are:

Full name of legal entity: Calmblue limited

Data Protection Officer: Lorraine White

Email address: lorraine@calmblue.org.uk

Postal address: Calmblue, 1 Canaan Lane, Morningside, Edinburgh EH10 4SZ

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@calmblue.org.uk.

2.  WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may includeyour username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data:

Your therapist will need to collect sensitive data about you during your appointment in order to treat you with the therapy that you have booked in for. You may be passed to a freelance therapist (data processor) but treated at our premises. All freelance therapists will have signed GDPR compliant processor agreements with us by 25/05/18.

When you book in via our website we only ask for contact information for the purposes of booking you in. You will be asked to read and sign a GDPR compliant Sensitive Data Privacy Notice when you see your therapist for the first time from 25/05/18 or before. The therapist will require your ‘explicit consent’ or ‘agreement to legitimate interests’ for processing sensitive data, before consulting with you.

Where we (the data controller), or the freelance therapist (the data processor), 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 (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
  • Order our products or services;
  • Create an account on our site;
  • Subscribe to our service or publications;
  • Request resources or marketing be sent to you;
  • Enter a competition, prize draw, promotion or survey; or
  • Give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, such as:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
• Search information providers.

 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:

• Where we need to perform the contract between us.
• 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.

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 emailing us at hello@calmblue.org.uk.

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 hello@calmblue.org.uk 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.

Marketing communications:

You will receive marketing communications from us if you have:

(i)              requested information from us or purchased goods or services from us; or

(ii)             if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and

(iii)            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 their marketing purposes.

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 emailing us at hello@calmblue.org.uk at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience 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 email us at hello@calmblue.org.uk.

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:

• Other companies in our group who provide IT and system administration services and undertake leadership reporting.
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting 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 sell, transfer, or merge parts of our business or our assets.

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.  INTERNATIONAL 

We share your personal data within our group of companies, which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at hello@calmblue.org.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the 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 such data. 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 

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 customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

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.

9.  YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• 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.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at hello@calmblue.org.uk.

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.

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.

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. 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.

11. 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 our cookie policy

HEALTH RELATED INFORMATION/SENSITIVE DATA PRIVACY NOTICE (FOR NEW/ONGOING CLIENTS SEEING LORRAINE WHITE)

Your personal information – General Data Protection Regulation (GDPR)

The ICO brought in new legal protection for personal information from May 2018. This tells you what personal information we hold, and why, and what your rights are. Once you have read it please complete and sign the declaration/statement of consent at the bottom.

Company Name: Calmblue Limited

Contact Details: 0131 446 3709 / 07721 599276, lorraine@calmblue.org.uk, 1 Canaan Lane, Edinburgh EH10 4SZ

Data Controller Contact Details: Lorraine White

The Purpose of processing Client Data

In order to give professional treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for treatments and associated recommendations concerning aspects of health and wellbeing that I will offer to you. We also take basic contact details and information via our website to allow us to contact you and handle bookings.

Lawful Basis for holding and using Client Information

As a full member of the Association of Reflexologists, I abide by the AoR Code of Practice and Ethics. The lawful basis under which I hold and use your information is: Legitimate interests

(My requirement to retain the information in order to provide you with the best possible treatment options.)

As I hold special category data (i.e. health related information), the Additional Condition under which I hold and use this information is: for me to fulfil my role as a health care practitioner bound under the AoR Confidentiality as defined in the AoR Code of Practice and Ethics.

What information I hold and what I do with it

In order to give professional treatments, I will need to ask for and keep information about your health. I will only use this for informing treatments and any advice I give as a result of your treatment. The information to be held is:

• Your contact details
• Medical history and other health-related information (which I will take from you at first consultation)
• Treatment details and related notes (which I will take after each consultation)

I will NOT share your information with anyone else other than within my own practice, or as required for legal process, without explaining why it is necessary, and getting your explicit consent.

It may be helpful for your treatment for me to share your information with practitioners working with me at Calmblue so that we can work together as a team, but we will only do that with your agreement. The information to be shared would be your basic contact details and any relevant health information that would be relevant to them in order to treat you. If you prefer, you can go through this with them yourself rather than via shared information.

How Long I Retain Your Information for

We will keep your information for seven years after your last treatment, if an adult, and until age 25 if 16 or under, and age 26 if age 17.

Your data will not be transferred outside the EU without your consent.

Protecting Your Personal Data

We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.

We will contact you using the contact preferences you give us in relation to:

– Appointment times                                                                    

– Treatment information or information related to your health   

– Special offers and promotions, if subscribed (you may unsubscribe from this at any time)

HEALTH RELATED INFORMATION/SENSITIVE DATA PRIVACY NOTICE (FOR PAST CLIENTS SEEING LORRAINE WHITE)

Your personal information – General Data Protection Regulation (GDPR)

The ICO brought in new legal protection for personal information from May 2018 This tells you what personal information we hold, and why, and what your rights are. Once you have read it please complete and sign the declaration/statement of consent at the bottom.

Company Name: Calmblue Limited

Contact Details: 0131 446 3709 / 07721 599276, lorraine@calmblue.org.uk, 1 Canaan Lane, Edinburgh EH10 4SZ

Data Controller Contact Details: Lorraine White

The Purpose of processing Client Data

In order to give professional treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for treatments and associated recommendations concerning aspects of health and wellbeing that I will offer to you. We also take basic contact details and information via our website to allow us to contact you and handle bookings.

Lawful Basis for holding and using Client Information

As a full member of the Association of Reflexologists, I abide by the AoR Code of Practice and Ethics. The lawful basis under which I hold and use your information is:

– Insurance    – Law regarding children’s records

(My requirement to retain the information in order to provide you with the best possible treatment options.)

As I hold special category data (i.e. health related information), the Additional Condition under which I hold and use this information is: for me to fulfil my role as a health care practitioner bound under the AoR Confidentiality as defined in the AoR Code of Practice and Ethics.

What information I hold and what I do with it

In order to give professional treatments, I will need to ask for and keep information about your health. I will only use this for informing treatments and any advice I give as a result of your treatment. The information to be held is:

• Your contact details
• Medical history and other health-related information (which I will take from you at first consultation)
• Treatment details and related notes (which I will take after each consultation)

I will NOT share your information with anyone else other than within my own practice, or as required for legal process, without explaining why it is necessary, and getting your explicit consent.

It may be helpful for your treatment for me to share your information with practitioners working with me at Calmblue so that we can work together as a team, but we will only do that with your agreement. The information to be shared would be your basic contact details and any relevant health information that would be relevant to them in order to treat you. If you prefer, you can go through this with them yourself rather than via shared information.

How Long I Retain Your Information for

We will keep your information for seven years after your last treatment, if an adult, and until age 25 if 16 or under, and age 26 if age 17.

Your data will not be transferred outside the EU without your consent.

Protecting Your Personal Data

We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.

We will contact you using the contact preferences you give us in relation to:

– Appointment times                                                                    

– Treatment information or information related to your health   

– Special offers and promotions, if subscribed (you may unsubscribe from this at any time)

Please email us to ackowledge that you have read and understood our Privacy Policies.

FURTHER INFORMATION

At Calmblue, we take your privacy seriously and will only use your personal information to effectively provide services that you have requested from us.

Online Booking

We ask for your name, email address and mobile number.

Your email address is needed so that you can receive a confirmation of booking and a reminder 24 hours before your session.

Your mobile number is required in case we need to call or text you before your treatment to ask you anything relating to your appointment, to contact you should we need to make any changes to your appointment, and so that you can receive a text reminder 24 hours before your session.

These details are seen by the therapist that you have requested to be booked in with, and the clinic administrators. All therapists listed on our website, except Lorraine White (owner and Managing Director of Calmblue / data controller), are freelancers (data processors). When we have booked you in with them, you become their client and you pay them directly. For future bookings you can either book in via Calmblue or directly with your therapist. If you wish to see a different therapist that practices at Calmblue you should contact Calmblue to be booked in.

The clinic administrator is genarally Lorraine White (data controller), but sometimes helped by longterm freelance assistants (data processors), who abide by our privacy notice and data protection.

All therapists will have their own privacy notices in place by 25/05/18, and you will receive a copy of it at the time of the session or beforehand by email if necessary or by request.

All freelancers (data processors) in our team will have GDPR compliant Processor Agreements with Calmblue by 25/05/18.

Gift Voucher Purchases (online, via email, telephone or in-person)

We ask for the recipients name and email address (if you have chosen to have the online voucher sent to them via email) or address (if you have chosen to have the voucher posted to them). Your card details are taken for online purchases for the payment via our secure online payment provider. The recipient’s details are passed to the Calmblue clinic administrator posting the gift voucher to the recipient if you have chosen this method of receipt.

Details taken in-person at Calmblue

When you come for your first session, Calmblue will ask you for your name, address, telephone numbers and email addess in order that we can contact you between sessions and/or in case of an emergency situation during your session.

You will be given the option to opt in to receive newsletters and offers periodically via email, and a Christmas card with voucher each year via post. You can unsubscribe from emails at any time via a link on the email. You can let us know if you would like to stop receiving Christmas cards from us by emailing us at hello@calmblue.org.uk.

Details Taken by the Therapist that you have booked in with

When you liase with or see the therapist that you have booked in with for the first time you will be given a GDPR compliant privacy notice to read, sign, and keep a copy of. Your information will be stored securely in paper and digital formats.

The therapist (either Lorraine White, Calmblue, or the freelance therapist that you have been booked in with) may be asking you for your contact details in order that they can contact you between sessions to discuss your treatments, your health history, GP contact details, and wellbeing questions in order to gain relevant information so that they can treat you effectively. If there is anything that you do not wish to answer, please let the therapist know at the time.

All therapists have their own GDPR compliant privacy notices, and have a GDPR compliant data processor agreements in place with Calmblue.

The sensitive data details you have provided us or your freelance therapist with will not be shared with any other parties, unless discussed and agreed with you first, and only for the benefit of your health and wellbeing. Full details of this will be on the privacy notice from the therapist. As all therapists except Lorraine White (owner and Managing Director of Camblue/data controller) are with us as freelancers (data processors), the privacy notices will be individual to them.

Lorraine White of Calmblue’s Privacy Notices for Health Related Information/Sensitive Data for new/ongoing clients and existing clients can be found above.

If you are a new or ongoing client of Lorraine White of Calmblue, you will be asked to sign the Privacy Notice for Health Related Information/Sensitive Data (above) at your session (just once, at our earliest convenience).

If you are a past client of Lorraine White of Calmblue, please read the Privacy Notice for Health Related Information (above) and email us at hello@calmblue.org.uk to confirm that you have read and understood the privacy policy.

If you would like a copy of the privacy notice of the freelance therapist that you have been booked in with by Calmblue, please email hello@calmblue.org.uk and we will email it to you.

If you have any further questions please email hello@calmblue.org.uk.

Please email us to ackowledge that you have read and understood our Privacy Policies.