Sif Health understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- UK Privacy and Electronic Communications (EC Directive) Regulations (PECR) 2003
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
This site's compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer for clarification at firstname.lastname@example.org
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
"Account" means an account required to access and/or use certain areas and features of Our Sites;
"Cookie" means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Site. Details of the Cookies used by Our Sites are set out in section 12, below;
"Our Sites" means the websites, https://www.sportsinjuryfix.com; https://sif.health and https://sifcpd.com.
"UK and EU" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
"We/Us/Our"means Sif Health, a limited company registered in England under company number 09980050, whose registered address is 113-116 Bute Street, Cardiff, CF10 5EQ.
2. Information About Us
Our Sites, https://www.sif.health, https://www.sportsinjuryfix.com and https://sifcpd.com are owned and operated by Sif Health Ltd, a limited company registered in England under company number 09980050, whose registered address is 113-116 Bute Street, Cardiff, CF10 5EQ. Our data protection officer can be contacted at email@example.com.
3. Scope - What Does This Policy Cover?
4. What Data Do We Collect?
- Date of birth;
- Business/company name;
- Job title;
- Contact information such as email addresses and telephone numbers;
- Demographic information such as post code, preferences and interests;
- Details of your health and medical condition and history;
- Details of your bookings with service providers;
- Details of client bookings and notes;
- Financial information such as credit / debit card numbers;
- IP address (automatically collected);
- Web browser type and version (automatically collected);
- Operating system (automatically collected);
- A list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to (automatically collected);
5. How Do We Use Your Data?
- All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below. We expect the same of any provider of services on our sites and those found not to will be removed from the site.
- We use your data to provide the best possible products and services to you. This includes:
- Providing and managing your Account;
- Providing and managing your access to Our Sites;
- Personalising and tailoring your experience on Our Sites;
- Supplying Our products and services to you;
- Personalising and tailoring Our products and services for you;
- Responding to communications from you;
- Supplying you with communications e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by updating your preferences in your account).
- Market research;
- Analysing your use of Our Sites [and gathering feedback] to enable Us to continually improve Our Sites and your user experience; For example identifying the level of load the server is under, what resources are being used and thus how we can keep everything running fast and securely;
In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
- 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;
- 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;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- 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 processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, 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.
6. How and Where Do We Store Your Data?
- We only keep your 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 annual reviews to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:
- We shall not keep any personal data longer than necessary, in relation to the purpose for which such data is processed.
- We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
Confidentiality means that only people who are authorised to use the data can access it. Integrity means that personal data should be accurate and suitable for the purpose for which it is processed. Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the company central computer system instead of individual PCs.
- From time to time, it may be necessary to retain or access historic personal data under certain circumstances such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation or business disaster recoveries.
- Upon expiry of our retention periods, we shall securely delete confidential or sensitive records categorised as requiring high protection and very high protection, and we shall either delete or anonymise less important documents.
- We will delete your patient records on expiration of your account as part of our GDPR policy. You must ensure you export it prior to account expiration.
- Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
- Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.
- Steps We take to secure and protect your data include, but are not limited to:
- Limited access to the data and minimise the numbers of people with admin access.
- All system level accounts are password protected with very strong passwords.
- Server has brute force detection and prevention functionality which automatically blocks any system level login attempts after so many failures. This is first an account level block soon followed by an IP level block.
- The file system uses encryption to store data securely and all backups are securely encrypted at a physical drive level.
- Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
- We may contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. 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, and the obligations of the third party under the law. We currently contract with: Active Campaign, HubSpot, Mail Chimp, Teachable, Freshdesk and Stripe.
- We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
9. How Can You Control Your Data?
- When you submit information via Our Sites, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details or by managing your Account).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10.Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
- You may access certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data
- You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org. or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.
12.How Can You Access Your Data?
Under the GDPR, you have:
- The right to request access to, deletion of or correction of, your personal data held by Us;
- The right to complain to a supervisory authority;
- Be informed of what data processing is taking place;
- The right to restrict processing;
- The right to data portability;
- Object to processing of your personal data;
- Rights with respect to automated decision-making and profiling (see section 14 below).
13. Automated Decision-Making and Profiling
13.1. 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.
13.2. The right described in section 14.1 does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of, a contract between the You and Us;
- The decision is authorised by law; or
- You have given you explicit consent.
13.3. We use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
14. Contacting Us