PERSONAL DATA WE COLLECT AND PROCESS
When registering for a user account, using any of The Salt Clinics Service and/or browsing the Website, we will collect and gather the following categories of personal data:
Identity Data such as first name, surname, gender, date of birth.
Contact Data such as address, e-mail address, telephone number.
Profile Data such as your username and password, personal data contained.
Financial Data: such as for Customers only, your payment card details, bank details, VAT number, information about payments to and from you and other details of services you have purchased from us.
Technical Data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
Usage Data such as information about how you use the Website and The Salt Clinic Services. Marketing and Communications Data such as your preferences in receiving marketing communications from us and third parties and your communication preferences. The type of personal data collected and used by us varies depending upon whether you are a registered user of just browsing the Website, or if you use one or more of The Salt Clinics services.
We collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered personal data under applicable data protection law as this data does not directly or indirectly reveal your identity.
HOW WE COLLECT PERSONAL DATA ON THE WEBSITE
In order to make an online appointment or purchase products or services through the Website, you will need to register an account with The Salt Clinic, which will involve you giving us your Identity, Contact and Profile Data. We will inform you at the time of collecting personal data from you whether you must provide the personal data to use the Website or a particular The Salt Clinic Service, or whether the provision of personal data requested by us is optional (e.g. providing your personal or professional interests and experiences with our products or services is optional). We will inform you at the time of collection whether your personal data will be accessible to other users of the Website or by third parties, so that you can decide whether to provide it.
It is not necessary to register a user account in order to search and view products or details about services we provide or view company profiles. However, we will receive Technical Data and Usage Data when you browse the Website. This is further explained below.
Methods used to collect personal data from and about you
Direct interactions: You may give us your Identity, Contact, Profile, Financial (Customers only), Marketing and Communications Data by populating your online profile, changing details in Your Account, filling in online forms or by communicating with us. The personal data we receive from direct interactions with you includes personal data you provide when you:
Apply or subscribe for our Website or other The Salt Clinic Service
Create a user account on our Website and when you add to and manage your personal profile;
Contact or communicate with us and/or Customers via the Website or other The Salt Clinic service
Request marketing communications to be sent to you
Automated technologies or interactions: As you interact with the Website, we collect Technical Data and Usage Data including details of your device, browsing actions and patterns, searches, job advertisements viewed, traffic data, web logs and other communication data and the resources that you access. We collect this personal data by using cookies, tracking codes, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.
Third parties: We may receive personal data about you from various third parties as set out below:
Technical Data from providers such as Google Analytics, Adobe Analytics, Adjust, Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Shedul, Mailchimp.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw your consent at any time by contacting us.
We do not request from you and we request you do not provide any special categories/sensitive personal data (e.g. personal data relating to racial or ethnic origin, political or religious opinions, membership of a trade union, or condition or sexual life or orientation). This type of personal data is subject to special protections under EU law.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.
We use your personal data in the following ways:
We will collect and use Identity; Contact and Technical Data to administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) which is necessary (i) for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) and (ii) to comply with a legal obligation;
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can opt out of any marketing communications from us at any time by emailing email@example.com
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURE OF PERSONAL DATA TO OTHERS
if you have indicated at registration, or at any time during your time as a user of the Website, that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, we will send you such offers or information. See Marketing above on how to change your preferences;
any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, where it is necessary to do so for the provision and administration of the services we provide to you;
we contract with other entities that perform certain tasks on our behalf and who are under our control (“Service Providers”).
This is required in order to provide and manage the Website and one or more service. Such Service Providers include IT systems suppliers and support, data storage, IT developers, insurance, credit card companies, payment processors, analytics companies, website hosting providers and other service providers;
professional advisors such as accountants, auditors, lawyers, bankers, insurers, and other outside professional advisors;
We will disclose your personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities or in order to enforce or apply our Terms and Conditions and other agreements, or to protect the rights, property, or safety of The Salt Clinic, our Customers, Website users or others. This includes exchanging personal data with third parties for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our Service Providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time that we notify you.
CUSTOMER CONTROL OF YOUR PERSONAL DATA
If a Customer to whom you or we have disclosed any of your personal data downloads or copies the personal data to a medium other than our Website, The Salt Clinic will no longer jointly control this personal data. Such data will be subject to the Customer’s own data protection and privacy practices. If you wish to understand the Customer’s data protection and privacy practices please contact the Customer directly. You will be able to exercise your Data Protection Rights directly with the Customer.
INTERNATIONAL DATA TRANSFERS
Where the country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where service providers are based in the US, we may transfer data to them if they are part of the EU-U.S. Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We will provide you on request a list of the countries located outside the EEA to which personal data may be transferred, and an indication of whether they have been determined by the European Commission to grant adequate protection to personal data. Where applicable, you are entitled, upon request to receive a copy of the relevant safeguard (for example, EC model contractual clauses) that has been taken to protect personal data during such transfer.
The Salt Clinic is committed to protecting the personal data you provide us. To prevent unauthorised access or disclosure of personal data under our control The Salt Clinic has appropriate security management systems in place to safeguard the personal data we collect.
Firewalls, intrusion detection and virus scanners are used on all parts of the Website. Encryption during transmission is also used on sections of the Website where security is particularly important.
While The Salt Clinic makes reasonable efforts to protect all personal data, no data transmission over the Internet can be guaranteed to be 100% secure. As a result The Salt Clinic cannot ensure or warrant the security of any personal data you transmit to us, you do so at your own risk. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby waive, release and discharge us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. You must not to share your Website password with anyone.
When you disclose personal data, or request us to make your personal data available, that personal data will be used by the Customer for its own purposes and such third party purposes and activities are beyond our control.
UPDATING YOUR PERSONAL DATA
It is important that the personal data we hold is accurate and current. Please keep us informed, using the Your Account section of the Website or alternatively let us know by using the Contact Us information below if any of your personal data changes during your relationship with us. It is your responsibility to keep your personal data up to date at all times.
LINKS TO THIRD PARTY WEBSITES
The Website contains links to and from the websites of our partner networks, Customers, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies.
We also use third party advertisements to support the Website. Some of these advertisers may use technology such as cookies and web beacons when they advertise on the Website, which will also send these advertisers (such as Google through the Google AdSense program) information including your IP address, your ISP, the browser you used to visit the Website, and in some cases, whether you have Flash installed. This is generally used for geotargeting purposes or showing certain ads based on specific sites visited.
IP ADDRESSES AND COOKIES
We may collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration and statistical purposes. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting the Website our computer server will
We retain personal data for no longer than is allowed under data protection law and, in any case, no longer than such personal data is necessary for the purpose for which it was processed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
As a registered user of the Website we will retain your Identity, Contact, Profile, Technical, Usage, Marketing and Communications Data for as long as your user account is live. We retain the personal data you provide while your account is in existence or as needed to provide you access to the Website and any The Salt Clinic Service you have used. Even if you only use the Website or any other The Salt Clinic Service occasionally, we will retain your Identity, Contact, Profile, Technical, Usage, Marketing and Communications Data until you decide to close your user account. In some cases we retain certain Usage Data (e.g. visitor and application statistics in a depersonalized or aggregated form). Also, we retain personal data for longer if required by applicable law or regulation or justified under applicable statutory limitation periods.
YOUR LEGAL RIGHTS
Under certain circumstances you have rights under applicable data protection law in relation to personal data, namely:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided.
Consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time if and to the extent we are relying on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Regarding your right to have your personal data erased, you can delete your user account with The Salt Clinic at any time. Deleting your user account deletes records of online purchase, and not your visiting history Once your user account is deleted, it is gone forever and cannot be restored. Some personal data however may still be stored and visible in other places on the Website. For example we need to keep a record of your visits and frequency to establish health performance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
In order to exercise one or more of your rights in respect of your personal data, you can do so by contacting us at firstname.lastname@example.org . We will respond to your request(s) as soon as reasonably practicable and within the legally required period of time.
You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (https://www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us in the first instance at email@example.com