We are committed to safeguarding the privacy of our website visitors and service users. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
For the purpose of the General Data Protection Rule ("GDPR"), any personal information provided or to be gathered by Umé Acupuncture is controlled by:
14 Lennox Road
You can contact us via our website contact form; by telephone, on the contact number published on our website; or by email, using the email address published on our website.
How secure is the information about me? We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
It is important for you to protect against unauthorised access to your password and to your computer. Please be sure to sign off when you finish using a shared computer.
In this section, we have summarised the rights that you have under data protection law. Your principal rights under data protection law are:
the right to access – you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free but additional copies may be subject to a reasonable fee.
the right to rectification – you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
the right to erasure – in some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
the right to restrict processing – in some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
the right to object to processing – have the right to ask us not to process your personal data for marketing purposes. We will usually inform you before collecting your data if we intend to use your data for such purposes. You have the right to object to our processing of your personal data for research or statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
the right to data portability – to the extent that the legal basis for our processing of your personal data is: a) consent; or b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps, at your request, prior to entering into a contract and such processing is carried out by automated means. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
the right to withdraw consent – you have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for research or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
the right to complain to a supervisory authority – you have the right to complain to your data protection regulator (in the UK) via the Information Commissioner’s Office.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us. If you want to exercise your rights, have a complaint, or just have questions, please contact us.
INFORMATION WE COLLECT
We may collect and process the following data about you:
“Usage Data” We may process data about your use of our website and services, which may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
“Account Data” We may process your account data, including your name, contact details and email address that you provide by filling in forms on our website or provided at the time of subscribing to our service or requesting further services. We may also ask you for information when you report a problem with our site. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
“Enquiry Data” We may process information contained in any enquiry you submit to us regarding goods and/or services, which may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
“Client Relationship Data” We may process information relating to our client relationships, including client contact information, which may be processed for the purposes of managing our relationships with clients, communicating with clients, keeping records of those communications and promoting our products and services to clients. The legal basis for this processing is our legitimate interests, namely the proper management of our client relationships.
“Notification Data” We may process information that you provide to us for the purpose of sending you relevant communications and/or notifications. The legal basis for this processing is consent.
“Correspondence Data” We may process information contained in or relating to any communication that you send to us, which may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
In addition to the specific purposes for which we may process your personal data, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person's personal data to us, unless we prompt you to do so.
DISCLOSING YOUR DATA
Information about our clients, their staff and customers is an important part of our business – we do not sell any data to third parties.. We do not share any of your personal data unless required to do so by law or to carry out our business contract with you.
Agents: We sometimes share your personal data with trusted third parties. We employ other companies and individuals to perform functions on our behalf. Examples include booking travel accommodation, flights, delivering packages, sending emails, removing repetitive information from customer lists, analysing data, providing marketing assistance, processing credit card payments and providing customer service.
Examples of the kind of third parties we work with are:
Operational companies such as airlines, hotels and local ground agents (worldwide, depending on country job taking place in), delivery couriers or associated suppliers;
Insurers and/or professional advisers (for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims)
IT companies who support our website and other business systems; and
Data insight companies to ensure your details are up to date and accurate.
With your consent: Other than as set out above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Your personal data may be transferred to countries outside the European Economic Area (EEA) for the purposes of carrying out any business contract we may have together, in particular when overseas travel arrangements are necessary. Personal data will only be shared with trusted third parties. Please note that these affiliates and companies have their own privacy policies, we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data.
The hosting facilities for our website are situated in United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://www.squarespace.com/dpa/.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
RETAINING AND DELETING PERSONAL DATA
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We’ll hold on to your information for as long as you have your account, or as long as is needed to be able to provide the services to you, or (in the case of any contact you may have with us) for as long as is necessary to provide support-related reporting and website traffic analysis only.
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide the services to you.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Notwithstanding the other provisions in this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
DATA PROTECTION OFFICER
We hope this Privacy Notice helps to explain how we handle your personal data and your rights to control it. If you have any questions that haven’t been covered, please contact our Data Protection Officer by email.
Last updated April 14, 2019