Alevere Ltd is committed to protecting the privacy of your personal data in accordance with Data Protection legislation. This Data Protection Notice (`Notice’) sets out the basis on which we will process your personal data.
In this Notice, ‘we’ (and any related expression) refers to: Alevere Limited registered in England & Wales, no. 07330002 whose registered office is The Orchards, Carleton, Carlisle, Cumbria CA1 3DZ.
The Data Protection Legislation
As from 25th May 2018, most personal data processing in the UK is subject to the EU General Data Protection Regulation (`GDPR’), as supplemented by UK legislation.
Personal data is any information that directly or indirectly identifies a living individual.
For the purposes of the GDPR, we will be the controller of any personal data that we collect from or about you in connection with the provision of our professional services, or related activities such as promoting the business and market research or, where relevant, dealing with new enquiries.
Under the GDPR, data controllers are required to process personal data lawfully, fairly and in a transparent manner, and in a manner that ensures appropriate security of the personal data. Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes, and the data must be adequate, relevant and limited to what is necessary in relation to those purposes, accurate and, where necessary, kept up to date, and kept in a form which permits identification of data subjects for no longer than is necessary for those purposes. Data controllers are responsible for, and must able to demonstrate, compliance with these principles.
Why we collect your personal data and what we do with it
Otherwise, we will keep your personal data for (1) administrative purposes (2) record keeping (3) supplying you with further information about Alevere® therapy (4) information about the services that other companies in the same group as Alevere Limited (5) to a registered medical practitioner for advice as to your suitability for Alevere® therapy (6) if there is an external audit (7) regulatory purposes.
Where we need to process special categories of data (`sensitive data’) or medical records relating to you, we will only do so with your explicit consent.
If you do not wish us to use your personal data in this way, please unsubscribe using the relevant link in the email that we send you. All future marketing communications will also contain a simple way to opt out of receiving any further marketing communications from us.
Who do we share your personal data with?
We will not use your personal data for any other purpose or disclose it to any third party, without your consent other than specified above unless we are required to do so by law.
Alevere Limited and Partner Clinic
Data processing services
Some of our data processing services are supplied by third party providers subcontracted to ourselves. Such third party suppliers will be appointed on the basis that they provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing will meet the requirements of the applicable Data Protection legislation and ensure the protection of the rights of the data subjects, and will carry out processing only on our written instructions, or where we have a legitimate interest in doing so, as indicated above.
Transferring our rights and duties
If there is a group re-organisation and administration or if our business is merged with or we are acquired by a third party, we will transfer our rights and duties under this policy to that third party..
Compliance with legal obligations
We may disclose your personal data if we are required to do so in order to comply with any legal or regulatory obligation or request, or where we have a legitimate interest in doing so, such as in order to enforce or apply our contract with you, to investigate potential breaches, or to protect our property and rights or those of others. This may include exchanging information with other companies and agencies for the purposes of credit risk reduction.
Transfers outside the EEA
In order to provide some of our professional services, we may share your personal data with one or more third party providers situated in countries outside the European Economic Area (including the USA) that do not have the same standards of Data Protection laws as the EU. We may do so with your consent, or where it is necessary for performance of the contract we have with you or for the establishment, exercise or defence of legal claims. However, we will ensure that contractual or other safeguards are in place to ensure that your personal data is adequately protected, and that enforceable rights and effective legal remedies are available for data subjects, and will inform you of the nature of these safeguards at the relevant time.
How long do we keep personal data for?
If you contact us with an enquiry about our professional services but you do not subsequently become a patient (or the company or other person you represent does not do so), it is our policy to keep your personal data unless you instruct us not to.
If you are or become a patient (or the company or other person you represent is or becomes a patient), we will retain contract information (including personal data) indefinitely.
In certain cases, it may not be physically possible to delete certain data (for instance, where it is stored on a secure external server), in which case we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.
Your rights as a data subject
As a data subject, you have certain legal rights (subject to certain exceptions under the Data Protection legislation) including the right:
· to access the personal data held about you and request a copy of it;
· to ask us not to process your personal data for marketing purposes;
· to withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your personal data on the basis of a consent that you have given (and not on some other legal basis);
· to ask us to rectify inaccurate personal data about you;
· to ask for the restriction of personal data about you that is inaccurate, unlawfully processed, or no longer required;
· to ask for the transfer of your personal data in a structured, commonly used and machine readable format where appropriate;
· to ask for the erasure of personal data about you where processing is no longer necessary, or the legitimate interests we have in processing your personal data are overridden by your interests, rights and freedoms as the data subject; and
· to make a complaint to the Information Commissioner’s Office which can be contacted by post via: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone via 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Changes to this Data Protection Notice
We may change this Data Protection Notice from time to time. In the case of any substantial change, we will notify you (where practicable) in writing or by email.
How to Contact Us
If you have any questions, comments or requests about this Data Protection Notice, or would like to exercise any of the rights you have, as set out above, please contact us:
· by email to: email@example.com; or
· by post to: The Data Protection Officer, Alevere Limited, c/o Silverlink Group, The Orchards, Carleton, Carlisle, Cumbria CA1 3DZ
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