Positive Reflex Therapy Privacy Policy

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This notice refers to personal data, which is defined as information concerning any individual (or Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA. This comes into effect 25 May 2018.

Name and Contact Details

Positive Reflex Therapy 

Tracy Lichtenstein 

St Albans, Hertfordshire, AL2 3XN

Email: tracy@positivereflextherapy.co.uk 

Tel: 07968 082920

Who is Positive Reflex Therapy?
Positive Reflex Therapy provides Reflexology & Reiki Treatments. Treatments are carried out in accordance with the Association of Reflexology’s Code of Conduct.

Personal Data
a) For the purposes of providing treatment, Positive Reflex Therapy may require detailed medical information. I will only collect what is relevant and necessary for your treatment. When you visit the practice, I will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Positive Reflex Therapy to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.

b) For marketing purposes, Positive Reflex Therapy may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.

c) In making initial contact with the practice you consent to Positive Reflex Therapy maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or I decide to desist in promoting Positive Reflex Therapy ’s services. Positive Reflex Therapy do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.

d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.

e) Positive Reflex Therapy’s website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. godaddy.com uses cookies to help Positive Reflex Therapy to identify and track visitors and their website access preferences. Positive Reflex Therapy's  website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Positive Reflex Therapy's  website.

f) Positive Reflex Therapy will only collect the information needed so that I can provide you with the services you require, the business does not sell or broker your data.

Legal basis for processing any personal data
To meet our contractual obligations obtained from Client Consent and legitimate interest to respond to enquiries concerning the services provided.

Legitimate interests pursued by Positive Reflex Therapy
To promote treatments for clients with all types of health problems including back pain and neck pain, tennis elbow, frozen shoulders, sciatica, headaches, sports injuries, and other degenerative conditions (to be used alongside traditional allopathic healthcare and not as a substitute) in addition to promoting treatments that promote sleep, relaxation and a sense of well-being.

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Consent
Through agreeing to this privacy notice you are consenting to Positive Reflex Therapy processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.

Disclosure
Positive Reflex Therapy will keep your personal information safe and secure, only I will have access to your client record. Positive Reflex Therapy will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.

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Retention Policy
Positive Reflex Therapy will process personal data during the duration of any treatment and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After seven years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.

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Data Storage

I will not transfer your data outside the EU without your consent. Google Cloud is committed to compliance with the EU GDPR across Google Cloud Platform services and more information can be found by clicking: https://cloud.google.com/security/gdpr

Protecting Your Personal Data 

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

I may contact you by email, text, WhatsApp or Facebook private message in relation to: 

• Appointment times
• Reflexology information or information related to your health
• News, special offers and promotions (you may unsubscribe from this at any time)

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Your rights as a data subject
At any point whilst Positive Reflex Therapy are in possession of, or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Positive Reflex Therapy refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Positive Reflex Therapy can confirm what information it holds about you and how it is processed.

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You can request the following information:

• Identity and the contact details of the person or organisation (Positive Reflex Therapy) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Positive Reflex Therapy and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

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Positive Reflex Therapy's rights

• If you don’t agree to me (your therapist) keeping records of information about you and your treatments, or if you don’t allow me to use the information in the way I need to for treatments, I may not be able to treat you.
• I have to keep your records of treatment for a certain period  as described above, which may mean that even if you ask me to erase any details about you, I might have to keep these details until after that period has passed.
• I can move your records between computers and IT systems, as long as your details are protected from being seen by others without your permission.

Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Positive Reflex Therapy you have the right to complain to me. If you do not get a response within 30 days, you can complain to the ICO. The details for each of these contacts are:

Tracy Lichtenstein, Positive Reflex Therapy

Email: tracy@positivereflextherapy.co.uk or telephone: 07968 082920

Information Commissioner's Office; their contact details are at: www.ico.org.uk