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Privacy Policy

 

Agreement: this contract.

 

Controller: the meaning given in the GDPR.

 

Data Loss Event: any event that results, or may result, in unauthorised access to Personal Data held by the Service Provider under this Agreement, and/or actual or potential loss and/or destruction of Personal Data in breach of this Agreement, including any Personal Data Breach.

Data Protection Impact Assessment: an assessment by the Controller of the impact of the envisaged processing on the protection of Personal Data.

Data Protection Legislation: (i) the DPA; (ii) the GDPR, the LED and any applicable national implementing Laws as amended from time to time; and (iii) all applicable Law about the processing of Personal Data and privacy.

Data Protection Officer: the meaning given in the GDPR.

Data Subject: the meaning given in the GDPR.

Data Subject Access Request: a request made by, or on behalf of, a Data Subject in accordance with rights granted pursuant to the Data Protection Legislation to access their Personal Data.

DPA: (i) the Data Protection Act 1998 and (ii) subject to Royal Assent, the Data Protection Act 2018 to the extent that it relates to processing of Personal Data and privacy.

GDPR: the General Data Protection Regulation (Regulation (EU) 2016/679).

Law: Any law, statute, subordinate legislation within the meaning of section 21(1) of the Interpretation Act 1978, bye-law, enforceable right within the meaning of section 2 of the European Communities Act 1972, regulation, order, mandatory guidance or code of practice, judgment of a relevant court of law, or directives or requirements of any regulatory body with which the Service Provider is bound to comply.

LED: the Law Enforcement Directive (Directive (EU) 2016/680).

Party: a Party to this Agreement.

Personal Data / Personal Data Breach: the meaning given in the GDPR.

Processor: the meaning given in the GDPR.

Protective Measures: appropriate technical and organisational measures which may include: pseudonym missing and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of any such measures adopted by it.

Service Provider's Personnel: all employees, staff, other workers, agents and consultants of the Service Provider and of any Sub-Contractors who are engaged in the provision of the Services from time to time. 

Sub-processor: any third Party appointed to process Personal Data on behalf of the Service Provider related to this Agreement.

 

  1. INTRODUCTION

This is our privacy policy. It tells you how we collect and process your personal data.

TRIX MEDCARE LTD is committed to protecting the privacy of our service users, and users of our website.

Please read the following carefully to understand your rights under the new General Data Protection regulation (GDPR) and our views and practices regarding your personal data and how we will treat it.

If you have any comments on this privacy policy, please email them to [email protected]

 

  1. 2. WHO WE ARE

When you use TRIX MEDCARE LTD, you trust us with your information as a ‘data controller’ and we are committed to preserving that trust and respecting your privacy.

We will ensure that the information you submit to us via our website or through any other means is only used for the purposes set out in this privacy policy.

 

 

  • Our company name is TRIX MEDCARE LTD under Companies House registration number 10123084   

 

  • Our registered address is 7 Brick Road, Great Wakering. Southend. Essex. SS3 0FQ.

 

  • Our Information Commissioner’s Office Registration number is ZA537040

 

  • Our Data Protection Officer is Sunday Kalejaiye who can be contacted at [email protected]
  1. WHAT DATA WE MAY COLLECT

We may collect and process the following data about you:

 

Website Users/Prospective Customers

  • Information you submit through forms or surveys on our site at any time
  • Personal information you have agreed to pass to us through third parties and agents
  • A record of any correspondence between us
  • Details of your enquiry
  • Details of your visits to our office and the resources you use

 

Existing Customers

  • Name & Address
  • Age
  • Date of birth
  • Name and address of next-of-kin
  • Name & Address of Surgery 
  • Name of GP
  • Name of other healthcare professionals
  • Medical history
  • Information about protected characteristics
  • Diagnosis & treatment regimen
  • List of allergies
  • Health information
  • Prescription/treatment information
  • Security codes
  • Sexual orientation
  • Religion
  • Telephone number
  • Biometric data
  • Images
  • A record of the correspondence between us
  • A record of the transactions between us
  • Copies of appropriate contracts in place between us

 

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

 

You have given consent to the processing of your personal data for one or more specific purposes;

  1. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  2. Processing is necessary for compliance with a legal obligation to which we are subject;
  3. Processing is necessary to protect the vital interests of you or of another natural person;
  4. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  5. Processing is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

COOKIES

All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.

The site uses cookies or similar technology to collect information about your access to the site. Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you.

A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last for longer.

 

All cookies used on our site are set by our IT provider.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.

 

Our cookies will be used for:

Essential session management:

  • Creating a specific log-in session for a user of the site in order that the site remembers that a user is logged in and that their page requests are delivered in an effective, secure and consistent manner;
  • Recognising when a user of the site has visited before allowing us to identify the number of unique users we receive to the site and make sure we have enough capacity for the number of users that we get;
  • Recognising if a visitor to the site is registered with us in any way;
  • We may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.

 

Functionality:

 

  • Customising content of the pages of the site.

 

Performance and measurement:

  • Collecting statistical information about how our users use the site so that we can improve the site and learn which parts are most popular to users.

 

  1. HOW WE USE WHAT WE COLLECT

We use information about you to:

  • Present website content effectively to you.
  • Provide information and services that you request.
  • Carry out our contracts with you.
  • Comply with specific legal obligations.
  • Allow you to use our interactive services if you want to.
  • Tell you our charges.

 

If you are already our customer, we will only contact you electronically about things similar to the services we already provide to you.

If you are an existing, customer and you do not want to be contacted for marketing purposes, please let us know at [email protected]

 

If you are a new customer, you will only be contacted if you agree to it.

In addition, if you do not want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at [email protected] and we will delete your data from our systems if it is appropriate to do so. However, you acknowledge this will limit our ability to provide the best possible services to you.

 

In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you do not provide your personal data in these cases.

 

  1. WHERE WE STORE YOUR DATA

We do not transfer your collected data to storage outside the European Economic Area (EEA).

We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

 

  1. DISCLOSING YOUR INFORMATION

We are allowed to disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer
  • We can disclose it if we have a legal obligation to do so.
  • We can exchange information with others to protect against fraud or credit risks.
  • We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that may have access to your information:
  • Sub-Processor (e.g. IT provider, Banker etc.)

 

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations under GDPR and the law.

 

Before allowing any sub-Processor to process your data to this agreement, we would have:

  • notified you in writing of the intended sub-processor and processing
  • obtained your written consent
  • entered into a written agreement with the sub-processor which give effect to the terms set out in this clause such that they apply to the sub-processor; and
  • provided the authority may reasonably require

 

TRIX MEDCARE LTD shall remain fully liable for all acts or omissions of any sub-processor

 

  1. YOUR RIGHTS

You can ask us not to use your data for whatever reason. You can do this by contacting us at any time at [email protected]

 

Under the GDPR, you have the right to:

  • Request access to, deletion of or correction of, your personal data held by us at no cost to you;
  • Request that your personal data be transferred to another person (data portability);
  • Be informed of what data processing is taking place;
  • Restrict processing;
  • To object to processing of your personal data; and
  • Complain to a supervisory authority

You also have rights with respect to automated decision-making and profiling as set out in section 11 below.

To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at [email protected]

 

  1. LINKS TO OTHER SITES

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

  1. CHANGES

If we change our Privacy Policy, we will post the changes to you. If we decide to, we may also email you.

 

  1. AUTOMATED DECISION-MAKING AND PROFILING

11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

11.2 The right described in section 11.1 does not apply in the following circumstances:

  1. a) The decision is necessary for the entry into, or performance of, a contract between the you and us;
  2. b) The decision is authorised by law; or
  3. c) You have given your explicit consent.

11.3 Where we use your personal data for profiling purposes, the following shall apply:

  1. a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  2. b) Appropriate mathematical or statistical procedures will be used;
  3. c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  4. d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

 

  1. DISPUTE RESOLUTION

12.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

12.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.

12.3 All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.

12.4 If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.

12.5 If the parties fail to resolve the dispute(s) within 30 working days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration by an arbitrator.

12.6 Any dispute shall not affect the parties’ ongoing obligations under this Privacy Policy.

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