Privacy Notice

IMPORTANT INFORMATION AND WHO WE ARE

1. Purpose of this privacy notice

   1. This privacy notice aims to give you information on how we collect and process your personal data when you engage us to provide you with services, via your use of our website or otherwise.
   2. It is important that you read this privacy notice together with any other privacy notice or fair processing 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 the other notices and is not intended to override them.
   3. This website and our services are not intended for children and we do not knowingly collect data relating to children.

2. Controller

   1. The Integrative Medic LTD., is a private limited company incorporated in England and Wales (under company number 14574237) whose registered office is at 20 Wenlock Road, London, England, N17GU, and for the purposes of data protection law, is the data ‘controller’ in respect of your personal data (collectively referred to as “we”, “us” and “our” in this privacy notice). We are responsible for ensuring that we use your personal data in compliance with data protection law and the relevant data protection principles.
   2. CONTACT US. 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.
   3. Email address: info@theintegrativemedic.com.

3. Complaints

   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.

THE DATA WE COLLECT ABOUT YOU

1. Personal data, or personal information, means any information about an individual from which that person can be identified. It includes sensitive personal information (such as information revealing ethnic or racial origin, physical or mental health conditions) and pseudonymised personal information (where information identifying an individual is replaced with artificial identifiers or pseudonyms), but does not include data where the identity has been removed (i.e., anonymous data).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
   1. Identity Data includes your first name, last name, date of birth and gender.
   2. Contact Data includes your postal address, email address and telephone number.
   3. Health Data includes notes, plans and other records about your health and wellbeing data that you provide to us as part of our patient take on process and as a result of individuals’ interactions with us in the course of providing our services, such as:
      1. notes relevant to your health;
      2. social history (such as relating to occupation); and
      3. results of any tests,
      each of the above in the context of, and as required, in the provision of our integrative medicine services (as defined in our general terms and conditions, which will be sent to you by email when you book a comprehensive Integrative Medicine consultation).
   4. Special Category Data related to your Health Data which includes information about your race, ethnicity, religious or philosophical beliefs to the extent that you provide us with such information during the provision of our services but only to the extent a record of such information is relevant to the provision of the integrative medicine services.
   5. Technical Data includes your internet protocol (IP) address, 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.
   6. Profile Data includes your preferences and survey responses.
   7. Transaction Data includes details about payments to and from you and other details of services you have purchased from us in order to keep a record of the transaction with you.
   8. Usage Data includes information about how you use our website and services.
   9. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3. We may also collect, use and share aggregated data such as statistical data or trends about the effectiveness of our services 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 feature on our website or using a specific service. 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.
4. Except for the Health Data and types of Special Category Data related to your Health Data listed in paragraph 2.2 above, we do not routinely collect or request any other special categories of personal data about you. Special categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, genetic and biometric data). We do not collect any information about criminal convictions and offences.

5. If you fail to provide personal data

   Where we need to collect personal data by law, or under the terms of a contract 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 our services). In that case, we may have to cancel the provision of services to you but we will notify you if that is the case at the time.

6. 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.

THIRD-PARTY LINKS

HOW IS YOUR PERSONAL DATA COLLECTED?

1. We use different methods to collect data from and about you including through:
   1. Direct interactions. You may give us your data by corresponding with us by phone, email, filling in forms on our website or otherwise. This includes personal data you provide when you:
      1. fill in our online forms;
      2. instruct us to provide you with any of the services we offer;
      3. provide us with information in order to allow us to provide you with our services or otherwise fulfil our obligations pursuant to any contract we have with you;
      4. respond to any survey we provide to you;
      5. request marketing to be sent to you; and/or
      6. give us any feedback or contact us.
   2. Automated technologies or interactions. If you interact with our website we may automatically collect Technical Data about your equipment or device, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy below for further details.
   3. Third parties or publicly available sources. We may receive personal data about you from third parties and public sources including, but not limited to:
      1. customer feedback tools provided by third party service providers;
      2. analytics providers such as Google; and
      3. Companies House,
      who may provide us with Identity Data and Contact Data.

HOW WE USE YOUR PERSONAL DATA

1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   1. Where we need to perform the contract we are about to enter into or have entered into with you.
   2. 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.
   3. Where you give us your consent to process the relevant personal data for a specified purpose.
   4. Where we need to comply with a legal or regulatory obligation.

2. Purposes for which we will use your personal data

   1. We have set out below, in a table format, a description of all the ways we plan to 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.
   2. Please note that while different lawful bases might apply to different purposes/activities, only one lawful basis is relied upon per specific sub-purpose/activity. Where we are relying on your consent to process your Health Data (see below for more details), in the event that you withdraw your consent to process such Health Data, we will stop processing and using your Health Data (i.e., we will not use another lawful basis to process such Health Data) but we may be required to retain a copy of your Health Data for legal purposes – please see paragraph 11.1 for further information. Please contact us via the means set out in paragraph 1.2.2 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.

      Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Special condition for processing of Health Data and other special category data (and basis in law to the extent relevant)
      To register/onboard you as a new patient	Identity Data, Contact Data, Health Data, Special Category Data, Transaction Data	Performance of a contract with you	You have provided your explicit consent, Health care purposes (to the extent relevant to the services to be provided to the patient)
      To provide you with our services	a) Identity Data, b) Contact Data, c) Health Data, Special Category Data, Finance Data, Profile Data, Transaction Data	Performance of a contract with you, You have provided your explicit consent	You have provided your explicit consent, Health care purposes (to the extent relevant to the services to be provided to the patient)
      To monitor and manage our relationship with you including: ongoing monitoring and to maintain our records; notifying you about proposed changes to this privacy notice; asking you to leave a review of our services or take a survey; and, “legal advice, legal proceedings, such as relating to any investigations and litigation. “	Identity Data, Contact Data, Marketing and Communications Data, Profile Data, Transaction Data, Finance Data, Special Category Data, Health Data, Profile Data	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, to ascertain how our customers use our services and to develop our services and grow our business)	You have provided your explicit consent, Establishment, exercise or defence of legal claims, Vital interests, Health care purposes (to the extent relevant to the services to be provided to the patient)
      To administer and protect our business and our website and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	a) Identity Data, b) Contact Data, c) Technical Data, Usage Data, Transaction Data	a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and in the context of a business reorganisation or group restructuring exercise), b) Necessary to comply with a legal obligation (including in the course of liaising with regulators and other authorities)	N/A
      To meet our professional, legal and regulatory obligations and to meet our insurance and audit requirements	Identity Data, Contact Data, Transaction Data, Health Data, Special Category Data	Performance of a contract with you, Necessary to comply with a legal obligation (including in the course of liaising with regulators and other authorities), Necessary for our legitimate interests (for running our business, to keep our records updated)	You have provided your explicit consent, Establishment, exercise or define of legal claims, Vital interests, Health care purposes (to the extent relevant to the services to be provided to the patient)
      To maintain our business relationship with you including communications, including making suggestions and recommendations to you about products or services that may be of interest to you (including those of third parties)	a) Identity Data, b) Contact Data, c) Technical Data, e) Usage Data, Profile Data, Marketing and Communications Data	Necessary for our legitimate interests (to develop our services and grow our business), You have provided your explicit consent	N/A
      To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we provide to you	Identity Data, Contact Data, Technical Data, Usage Data, Marketing and Communications Data, Transaction Data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy), You have provided your explicit consent	N/A

3. Change of purpose

   1. 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 via the means set out in paragraph 1.2.2.
   2. 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.
   3. 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.

4. Marketing

   1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
   2. We may use your data to form a view on services that 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 (we call this marketing).
   3. You will receive marketing communications from us if you have a pre-existing business relationship with us (for example, you have requested information from us or signed up to receive a newsletter) or you have or engaged us to provide you with services and, in each case, you have not opted out of receiving that marketing.

5. Third-party marketing

   We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

6. Opting-out

   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 contacting us via the means set out in paragraph 1.2.2.

COOKIES

DISCLOSURES OF YOUR PERSONAL DATA

1. Internal Third Parties as set out in the Glossary to this privacy notice.
2. External Third Parties as set out in the Glossary to this privacy notice.
3. Other external parties such as the police, fire and rescue services if:
   1. there is an immediate risk of harm to you or other people; or
   2. there is a legal requirement to do so e.g. the police have obtained a court order requiring us to provide information.
4. 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.

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

1. How long will you use my personal data for?

   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, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for your 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, regulatory, tax, accounting or other requirements. We have to keep certain information about our patients (i.e., each patient’s Contact, Health, Special Categories of personal data relating to Health Data, Identity and Transaction Data) for seven years after they cease being a patient of ours for legal, regulatory and insurance purposes. In some circumstances you can ask us to delete your data: see Request erasure 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.

Your LEGAL rights

1. 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.
2. 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.
3. 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 or regulatory reasons which will be notified to you, if applicable, at the time of your request.
4. 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.
5. 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:
   1. If you want us to establish the data’s accuracy.
   2. Where our use of the data is unlawful but you do not want us to erase it.
   3. 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.
   4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. 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.
7. Withdraw consent at any time where we are relying on consent to process your Health 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.

No fee usually required

What we may need from you

Time limit to respond

GLOSSARY

• Service providers acting as data processors who provide us with payment processing services; consultancy services; IT, system and patient administration services.
• Conventional medicine general practitioners and other clinicians.
• Integrative medicine therapists and specialists.
• Professional advisers including solicitors, auditors and insurers who provide us with legal, accounting, regulatory/compliance and insurance services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.