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LEDBURY PODIATRY PRIVACY POLICY
This Privacy Policy describes Ledbury Podiatry's practices regarding the collection,
use and disclosure of the information we collect from and about you when you use
Ledbury Podiatry’s website, mobile applications, social media, products and
services.
By accessing or using the services, you agree to this Privacy Policy.
IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE
SERVICES.
This Privacy Policy contains the following sections:
● The Information We Collect
● How We Use Your Information
● Cookies and Similar Technologies
● Online Analytics and Advertising
● How We Share and Disclose Your Information
● Your Choices
● Third Party Links and Services
● Children’s Privacy
● International Transfer of Data
● Your Rights
● How Long We Store Your Information
● Changes to Our Privacy Policy
● How We Protect Your Information
● Infinite Podiatry & Physio Ltd Contact Information
THE INFORMATION WE COLLECT
Ledbury Podiatry collects a variety of information that you provide directly to us. We
process your information, when necessary, to provide you with the services that you
have requested when accepting our Terms of Service, or where we have obtained
your prior consent, or where we have a legitimate interest to do so. For example, we
may have a legitimate interest to process your information to be able to provide
treatment, invoice & billing, and enhancement purposes of the services we provide to
you, or for analytics, research, and reporting purposes. Without your information, we
cannot provide you with the services you have requested or you may be limited in
your use of the services.
1. Information You Provide to Us
Ledbury Podiatry collects information from you through:
● Patient Enquiries and Registration
● The Ledbury Podiatry services that you use
● Requests or questions you submit to us via forms or email (e.g., website
enquiries, website chat enquiry, direct email, facebook messenger).
● Your communications and dealings with us.
● Uploads or posts to social media, website & use of service.
● Requests for information through 3rd parties or 3rd party referrals
assistance.
Information from and about you:
The types of information we collect will depend upon the services you use, how you
use them, and what you choose to provide.
The types of data we collect directly from you may include:
● Name, address, D.O.B, telephone numbers and email address.
● Optional information may include photographs, patient relationships,
referral sources etc.
● Any email requests or questions you submit to us.
● Demographic information such as your gender, age, etc.
● User-generated content you post in public online platforms.
Content:
We are required to generate records of all treatment provided. The HCPC – Health
and Care Professions Council mandate that all data must be kept for a period no
shorter than seven years.
This does not impede your right to be forgotten. We are able to archive your content
upon your request, but your patient records and notes must be kept in line with
HCPC guidelines.
Information about others:
If you choose to recommend our services online, via social media, or use our online
referral service we will use that person’s contact information, which may include their
email address or their social network identity, to send an invitation. Ledbury Podiatry
stores the information you provide to send the invitation & to register that person.
2. Information We Automatically Collect
When you use our services that connect to the Internet, including, but not limited to,
when you access the services via our website, your mobile devices, we automatically
collect certain information as described in this section.
As discussed further below, we and our service providers (which are third party
companies that work on our behalf to provide and enhance the services) use a
variety of technologies, including cookies and similar tools, to assist in collecting this
information.
Log Files:
When you use the services, our servers automatically record certain information in
server logs. These server logs may include information such as your web request,
Internet Protocol (“IP”) address, browser type and settings, referring / exit pages and
URLs, number of clicks and how you interact with links on the services, metadata
associated with uploaded Content, domain names, landing pages, pages viewed,
mobile carrier, date and time stamp information and other such information.
Device Identifiers:
When you access the services using a mobile device, we collect specific device
information, including your MAC address and other unique device identifiers. We
also collect information such as the type of device you are using, its operating
system, and mobile network information, which may include your mobile phone
number. We may associate this device identifier with your account and will use data
associated with your device identifier to customize our services to your device and to
analyze any device-related issues.
Location Information:
We collect and process general information about the location of the device from
which you are accessing the Service (e.g., approximate geographic location inferred
from an IP address).
3. Information We Collect From Third-Party Integrations
When you use third-party integrations (e.g., Facebook Messenger, Slack, Calendly,
Asana, Physi-track etc), such providers may allow us to have access to and store
additional information about your interaction with those services and platforms as it
related to use of the services. If you do not wish to have this information shared, do
not initiate these connections.
4. Information We Collect from Affiliates and Non-Affiliated Third Parties
Ledbury Podiatry may receive additional information about you, such as
demographic information from third parties, such as business partners, marketers,
researchers, analysts, and other parties (e.g facebook) that we may use to
supplement the information that we collect directly from you.
COOKIES AND SIMILAR TECHNOLOGIES
To collect the information in the “Information We Automatically Collect” section
above, we and our service providers use Internet server logs, cookies, tags, SDKs,
tracking pixels, and other similar tracking technologies. A web server log is a file
where website activity is stored. An SDK is a section of code that we embed in our
applications and software to allow third parties to collect information about how users
interact with the services. A cookie is a small text file that is placed on your computer
or mobile device when you visit a site, that enables us to: (i) recognize your
computer and login session; (ii) store your preferences and settings; (iii) understand
which web pages of the services you have visited; (iv), enhance your user
experience by delivering and measuring the effectiveness of content and advertising
tailored to your interests; (v) perform analytics; and (vi) assist with security and
administrative functions. Tracking pixels (sometimes referred to as web beacons or
clear GIFs) are tiny electronic tags with a unique identifier embedded in websites,
online ads and/or email, and that are designed to provide usage information like ad
impressions or clicks, email open rates, measure popularity of the services and
associated advertising, and to access user cookies. As we adopt additional
technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a cookie is being
set or updated, or to block cookies altogether. Please consult the “Help” section of
your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla
Firefox; or Apple Safari).
HOW WE USE YOUR INFORMATION
We use your information (including any information that we collect, as described in
this Privacy Policy) for various purposes depending on the types of information we
have collected from and about you and the specific Ledbury Podiatry services you
use, including to:
● Provide the services you have requested.
● Respond to your request for information and provide you with more
effective and efficient customer service.
● Provide you with product updates and information about products &
services you have purchased from us.
● Provide you with service notifications via email and SMS.
● Contact you by email, postal mail, or phone regarding Ledbury Podiatry
and third-party products, services, surveys, research studies, promotions,
special events and other subjects that we think may be of interest to you.
● Customize the advertising and content you see.
● Help us better understand your interests and needs and improve our
services.
● Synthesize and derive insights from your use of different Ledbury Podiatry
products and services.
● Engage in analysis, research, and reports regarding use of our services.
● Provide, manage, and improve the services.
ONLINE ANALYTICS AND ADVERTISING
1. Analytics
We use third-party web analytics services (e.g. Google Analytics) on our services to
collect and analyse the information discussed above, and to engage in auditing,
research and reporting. The information (including your IP address) collected by
various analytics technologies described in the “Cookies and Similar Technologies”
section will be disclosed to or collected directly by these service providers.
2. Online Advertising
Third parties or affiliates may administer Ledbury Podiatry banner advertising
programs and other online marketing on non-Ledbury Podiatry websites and
services. To do so, these parties may set and access first-party cookies delivered
from a Ledbury Podiatry domain, or they may use third-party cookies or other
tracking mechanisms. For example, a third-party provider may use the fact that you
visited the Ledbury Podiatry website to target online ads for Ledbury Podiatry
services to you on non-Ledbury Podiaty websites. Or a third-party ad network might
collect information on the services and other websites to develop a profile of your
interests and target advertisements to you based on your online behaviour. These
parties that use these technologies may offer you a way to opt out of ad targeting as
described below. You may receive tailored advertising on your computer through a
web browser.
HOW WE SHARE YOUR INFORMATION
Ledbury Podiatry will share your information in the following ways:
● Service Providers.
We may provide access to or share your information with select third
parties who perform services on our behalf. These third parties provide a
variety of services to us, including without limitation product manufacture,
billing, sales, marketing, provision of content and features, advertising,
analytics, research, customer service, shipping and fulfilment, data storage,
security, fraud prevention, payment processing, and legal services.
● Third-Party Integrations.
When you initiate a connection with a third-party integration through the
services (e.g. Facebook Messenger, Calendly, Physi-Track, Asana etc), we
will share information about you that is required to enable your use of the
third-party integration through the services.
● Business Transfers.
If the ownership of all or substantially all of our business changes, we may
transfer your information to the new owner so that the services can
continue to operate. In such case, your information would remain subject to
the promises and commitments contained in this Privacy Policy until such
time as this Privacy Policy is updated or amended by the acquiring party
upon notice to you. If such transfer is subject to additional mandatory
restrictions under applicable laws, Ledbury Podiatry will comply with such
restrictions.
● Public Forums.
The services make it possible for you to upload and share comments or
feedback publicly (i.e., outside of the Ledbury Podiatry mobile and web
app) with other users, such as on the Ledbury Podiatry social media, blogs
etc. Any information that you submit through such public features is not
confidential, and Ledbury Podiatry may use it for any purpose (including in
testimonials or other Ledbury Podiatry marketing materials). Any
information you post openly in these ways will be available to the public at
large and potentially accessible through third-party search engines. Such
information can be read, collected and/or used by other users, and it could
be used to send you unsolicited messages. Accordingly, please take care
when using these features of the services.
● Aggregate/De-Identified Information.
From time to time, Ledbury Podiatry may share Aggregate/De-Identified
Information about use of the services, such as by publishing a report on
usage trends. As stated above, this Policy places no limitations on our use
or sharing of Aggregate/De-Identified Information.
● Consent.
We may also disclose your information to third parties with your consent to
do so. For example, we will write to your GP to update them on your
treatment but only with your consent.
YOUR CHOICES
We provide you with a number of choices with respect to the information we collect
and use as discussed throughout this Privacy Policy. For example: – You may
instruct us not to use your contact information to contact you by email, postal mail or
phone regarding products, services, promotions and special events that might
appeal to your interests by contacting us at any time.
In commercial email messages, you can also opt out by following the instructions
located at the bottom of such emails.
Please note that, regardless of your request, we may still use and share certain
information as permitted by this Privacy Policy or as required by applicable law. For
example, you may opt out of certain operational or service-related emails, such as
those reflecting our relationship or transactions with you, but we have to retain your
medical records for a period of at least seven years.
THIRD PARTY LINKS AND SERVICES
The services contain links to third-party websites such as social media sites, and
also contain third-party integrations. If you choose to use these sites or integrations,
you may disclose your information not just to those third-parties, but also to their
users and the public more generally depending on how their services function.
Because these third-party websites and services are not operated by Ledbury
Podiatry, Ledbury Podiatry is not responsible for the content or practices of those
websites or services. The collection, use, and disclosure of your personal and other
information will be subject to the privacy policies of the third party websites or
services, and not this Policy. We urge you to read the privacy and security policies of
these third-parties.
CHILDREN’S PRIVACY
Our services are available to all ages. For children under 16, we may need to get
consent from someone with parental responsibility. This could be: − the child’s
mother or father; − the child’s legally appointed guardian; − a person with a
residence order for the child; − a local authority designated to care for the child; or −
a local authority or person with an emergency protection order for the child.
However, some children under 16 can give consent if they can fully understand the
information given to them. This is known as ‘Gillick competence’.
INTERNATIONAL TRANSFER OF DATA
Ledbury Podiatry complies with EU General Data Protection Regulation (GDPR).
The GDPR imposes restrictions on the transfer of personal data outside the
European Union, to third countries or international organisations, in order to ensure
that the level of protection of individuals afforded by the GDPR is not undermined.
Personal data may only be transferred outside of the EU in compliance with the
conditions for transfer set out in Chapter V of the GDPR. Transfers may be made
where the Commission has decided that a third country, a territory or one or more
specific sectors in the third country, or an international organisation ensures an
adequate level of protection. Any data that leaves the EU and is processed in the
United States of America is protected under the EU-US Privacy Shield Framework
and the Swiss-US Privacy Shield Framework as set forth by the EU parliament and
the UK’s Information Commissioner’s office regarding the collection, use, and
retention of personal information from the European Union and Switzerland to the
United States.
In compliance with the GDPR, EU-US Privacy Shield and Swiss-US Privacy Shield
Principles, Ledbury Podiatry commits to resolve complaints about your privacy and
our collection or use of your personal information. European Union or Swiss citizens
with enquiries or complaints regarding this privacy policy should first contact Ledbury
Podiatry at Ledburypodiatry.com
We may transfer information that we collect about you to third party processors
across international borders outside the EU. These third parties may have access to
your information for the limited purpose of providing the service we have contracted
with them to provide. They are required to have a privacy policy and security
standards in place that are at least as protective of your information as is this Privacy
Policy (including those provisions related to compliance with the EU-US and
Swiss-US Privacy Shield). Ledbury Podiatry will take reasonable and appropriate
steps necessary to ensure that any third party who is acting as a “data processor”
under EU and Swiss terminology is processing the personal information we entrust
to them in a manner that is consistent with the EU-US and Swiss-US Privacy Shield
Principles.
YOUR RIGHTS
If you want to learn more about the information collected through the services, or if
you would like to access or rectify your information and/or request deletion of
information we collect about you, or restrict or object to the processing of your
information, please contact us using the contact information below. You may have to
make a ‘Subject Access Request’ This is covered in the ICO’s Subject Access
Request Policy which is available on request. Where you have provided consent,
you may withdraw your consent at any time, without affecting the lawfulness of the
processing that was carried out prior to withdrawing your consent. If you are
dissatisfied with the way we process your information, you may lodge a complaint
with the ICO (Information Commissioner’s Office) the UK’s independent body set up
to uphold information rights.
HOW LONG WE STORE YOUR INFORMATION
We will retain your information for the period necessary to fulfil the purposes outlined
in this Policy unless a longer retention period is required or permitted by law.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this Policy at any time to reflect changes in the law,
our data collection and use practices, the features of our services, or advances in
technology. We will make the revised Policy accessible through the services, so you
should review the Policy periodically. If we make a material change to the Policy, you
will be provided with appropriate notice and we will seek your consent to the updated
Policy in accordance with legal requirements.
HOW WE PROTECT YOUR INFORMATION
Ledbury Podiatry takes technical and organisational measures to protect your
personal data against accidental or unlawful destruction or accidental loss, alteration,
unauthorized disclosure or access. However, no method of transmission over the
Internet, and no means of electronic or physical storage, is absolutely secure, and
thus we cannot ensure or warrant the security of that information. If you have any
questions about security on our services, you can contact us at