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  1. Introduction

    1. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
    2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
    3. In this policy, “we”, “us” and “our” refer to DermaPharm Aesthetics. For more information about us, see Section 14.
    4. Any data collected will be used in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and the privacy and Electronic Communication Regulations 2003. Information gathered will not be shared with any Third Party companies for direct marketing.
  2. The personal data that we collect

    1. The personal information we collect includes your name, date of birth, home address, email address, contact telephone number, emergency contact details, and credit or debit card payment information. If you have attended DermaPharm aesthetics for an appointment in the past, we will have a record of that previous contact.
    2. The medical information our doctor collects is specifically about your personal health. This includes information about your past medical history, any current medicines you are taking, and a description of the health issue that you are experiencing that could affect the suitability of treatments.
    3. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
    4. We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data 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.
  3. How do we use your information?

    1. DermaPharm Aesthetics collects and holds personal information for the sole purpose of providing aesthetics-related healthcare services to patients. Your personal information is used to identify you as a patient who has used the DermaPharm Aesthetics independent health service.
    2. Your credit or debit card information is used to allow DermaPharm Aesthetics to receive payment for your appointment. We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
    3. Your medical information is used by our doctor to recommend the best treatment for you.
    4. We use patients’ healthcare records to audit and monitor the quality of the service. For example, we may audit the records of patients who have had a particular treatment to see how well it has worked. When we carry out any audits, we never use any information that could identify a patient such as a name, address, or date of birth.
  4. Who has access to your information?

    1. The processing of your personal information and medical information is accessed only by the DermaPharm Aesthetics staff. Every member of staff who works for DermaPharm Aesthetics has a legal obligation to keep information about you confidential. Our staff include medical practitioners, a manager, administration or reception staff.
    2. Your medical information may be shared with another healthcare specialist outside of DermaPharm Aesthetics if our doctor feels that you would benefit from seeing a health specialist. Such healthcare specialists may be based within the National Health Service (NHS) or at another independent healthcare provider. However, this will only be done after our doctor has explained this to you and only if you give your consent to do so.
    3. We ensure that all information we hold is kept confidential. However, we are obliged to disclose personal information if it is required by law, or it is justified in the public interest.
    4. We do not sell or rent your personal information to any third parties outside of DermaPharm Aesthetics. We do not share your information with any third parties for marketing purposes.
  5. Consent and agreement

    1. By agreeing to this privacy notice, you are giving DermaPharm Aesthetics permission to process your personal data specifically for the purposes identified. You are able to withdraw your consent at any time. Please contact us if you wish to discuss this.
  6. Purposes of processing and legal bases

    1. In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
    2. Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment- related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
    3. Publications – We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent OR our legitimate interests, namely the publication of content in the ordinary course of our operations OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
    4. Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
    5. Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
    6. Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
    7. Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
    8. Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
    9. Insurance and risk management – We may process your personal data where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. 4.10 Legal claims – We may process your personal
    10. Legal compliance and vital interests – We may also process 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.
  7. Providing your personal data to others

    1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
    2. We may disclose data obtained through booking to our suppliers or subcontractors identified at Dermapharmaesthetics.com insofar as reasonably necessary for to complete transaction.
    3. Financial transactions relating to our website and services are OR may be handled by our payment services providers, TimelyPay, STRIPE, GoCardless, MONZO. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at stage2.dermapharmaesthetics.com.
    4. In addition to the specific disclosures of personal data set out in this Section 4, 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.
  8. International transfers of your personal data

    1. In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law.
    2. The hosting facilities for our website are situated in UK. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of this country.
    3. 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.
  9. Retaining and deleting personal data

    1. This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. 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.
    3. We will retain your personal data as follows:
      • contact data will be retained for a minimum period of 5 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
      • account data will be retained for a minimum period of 5 years following the date of closure of the relevant account, and for a maximum period of 10 years following that date;
      • transaction data will be retained for a minimum period of 5 years following the date of the transaction, and for a maximum period of 10 years following that date;
      • communication data will be retained for a minimum period of 5 years following the date of the communication in question, and for a maximum period of 10 years following that date;
      • usage data will be retained for 5 years following the date of collection; and
      • Medical data will be retained for a minimum period of 5 years following date of the communication, and for a maximum period of 10 years following date.
    4. Notwithstanding the other provisions of this Section 7, 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.
  10. Your rights

    1. In this Section 8, we have listed the rights that you have under data protection law.
    2. Your principal rights under data protection law are:
      • the right to access – you can ask for copies of your personal data;
      • the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      • the right to erasure – you can ask us to erase your personal data;
      • the right to restrict processing – you can ask us to restrict the processing of your personal data;
      • the right to object to processing – you can object to the processing of your personal data;
      • the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
      • the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
      • the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines- recommendations-best-practices_en and https://ico.org.uk/for- organisations/guide-to-data-protection/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/].
    4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
  11. About cookies

    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
    4. No Cookies are used at stage2.dermapharmaesthetics.com
  12. Cookies used by our service providers

    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy
  13. Amendments

    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of significant changes to this policy by email.
  14. Our details

    1. This website is owned and operated by DermaPharm Aesthetics.
    2. We are registered in England and Wales under registration number 10513348, and our registered office is at 4 Alford Lane, Stockton-On-Tees, TS19 0QP.
    3. Our principal place of business is at 39 Harley Street.
    4. You can contact us:
      • by post at 4 Alford Lane, Stockton-On-Tees, TS19 0QP;
      • by telephone, on the contact number published on our website; or
      • by email, using the email address published on our website.
  15. Representatives

    1. Our representative within the UK with respect to our obligations under data protection law is the Clinic Manager and you can contact our representative by email at [email protected].
  16. Data protection officer

    1. Our data protection officer’s contact details are: Clinic Manager, email [email protected].