PRIVACY POLICY
This Privacy Policy describes Footcare in the Square’s practises regarding the collection, use and disclosure of the information we collect from and about you when you use Footcare in the Square’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 OUR 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
- Footcare in the Square Contact Information
- The Information We Collect
Footcare in the Square collects a variety of information that you provide directly to us. We process your information to provide you with the services that you have requested when accepting our Terms and Conditions 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 your treatment, invoice and billing, enhancement of the services we provide to you, 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 services.
Information You Provide To Us:
Footcare in the Square collects information from you through:
- Patient Enquiries and Registration.
- The services provided by Footcare in the Square that you use.
- Requests or questions you submit to us via forms or email (e.g. website, enquiries, website message enquiry, direct email, Google).
- Your communications and dealings with us.
- Your participation in Footcare in the Square research studies.
- Uploads and posts to social media, website and 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 service you use, how you use them and the information you choose to provide.
The types of data we collect directly from you may include:
- Name, address, date of birth, 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 Royal College of Podiatry recommends we retain data for a period no shorter than eight 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 these guidelines.
Information We Automatically Collect:
When you use the services that connect to the internet, including but not limited to when you access the services via our website, your mobile devices, any Footcare in the Square software/applications, we automatically collect certain information as described in this section. As set out below, we and our service
providers (which are third party companies that work on our behalf to provide and enhance our services) use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
Log Files:
When you use the services, the 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 service, meta data 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, it’s 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 customise our services to your device and to analyse 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. Google, Facebook click funnels, Messenger, Instagram, Linkedin 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 our services. If you do not wish to have information shared, do not initiate these connections.
4. Information We Collect from Affiliates and Non-Affiliated Third Parties:
Footcare in the Square may receive additional information about you such as demographic information from third parties such as business partners, marketers, researchers, analysts and social media 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:
- Recognise your computer and login session;
- Store your preferences and settings;
- Understand which web pages of the services you have visited;
- Enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests;
- Perform analytics;
- 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, 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 Footcare in the Square services you use. We also use your information 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 and services you have purchased from us.
- Provide you with service notifications via email and SMS.
- Contact you by email, postal mail or phone regarding Footcare in the Square products, services, surveys, promotions, 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.
- Engage in analysis, research and reports regarding use of our services.
- Provide, manage and improve the services.
ONLINE ANALYTICS AND ADVERTISING
Analytics:
We use third-party web analytics services (e.g. Google Analytics) on our services to collect and analyse the information discussed about, 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.
Online Advertising:
Third parties or affiliates may administer Footcare in the Square banner advertising programs and other online marketing on non-Footcare in the Square websites and services. To do so, these parties may set and access first-party cookies delivered from Footcare in the Square 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 Footcare in the Square websites. Further, 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. Parties that use these technologies may offer you a way to opt of ad targeting as described below.
You may receive tailored advertising on your computer through a web browser. Footcare in the Square 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 parties provide a variety of services to us including and 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 these services (e.g. Google, Facebook Messenger, Facebook click funnels, landing pages, Instagram 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, Footcare in the Square will comply with such restrictions.
- Public Forms – The services make it possible for you to upload and share comments or feedback publicly (i.e. outside of the Footcare in the Square mobile and web app) with other users, such as on Footcare in the Square social media, blogs etc. Any information that you submit through such public features is not confidential and Footcare in the Square may use it for any purpose (including testimonials or other Footcare in the Square 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, Footcare in the Square 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 disclose your information to third parties only 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 bottoms of such emails.
Please note, 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 eight 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 chose 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 Footcare in the Square, Footcare in the Square is not responsible for the content of 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 will 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
Footcare in the Square 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, Footcare in the Square 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 Footcare in the Square at: footcareinthesquare@yahoo.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 third 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).
Footcare in the Square 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-ES 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 our 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 the Privacy Policy unless a longer retention period is required or permitted by law.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and usage 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 Privacy Policy, you will be provided with appropriate notice and we will seek your consent to the updated Privacy Policy in accordance with legal requirements.
HOW TO PROTECT YOUR INFORMATION
Footcare in the Square 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, thus we cannot ensure or warrant the security of that information. If you have any questions about security of our services, you can contact us as footcareinthesquare@yahoo.com
FOOTCARE IN THE SQUARE CONTACT INFORMATION
The data controller of your information is David Forster, located at Footcare in the Square, 62 Hamilton Square, Birkenhead, CH41 5AT.
If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please email us at footcareinthesquare@yahoo.com or call 0151 647 7498.
