Privacy Policy

This is BWR Synergy Health Limited’s Privacy Policy. For the purposes of data protection laws, we are deemed to be the “data controller” and respect your privacy and are committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit our website (regardless of what country you visit it from) and tell you about your data privacy rights and how the law protects you. We will keep our Policy under review and this current version is dated 24^th October 2022. It is also important that the personal data we hold about you is accurate and current so please keep us informed if your personal data changes during your relationship with us.

This Policy aims to give you information on how we collect and processes your personal data through your use of our website, including any data you may provide through the website when you make an enquiry, sign up to our newsletter or purchase services. This website is not intended for children, and we do not knowingly collect data relating to children. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies.

1. How do I get in touch?

We have a Data Privacy Manager who will manage any questions in relation to this Policy and they can be contacted by email at data@bwrsynergyhealth.com. We will seek to resolve any issues or complaints in a timely manner, and whilst you can contact the Information Commissioner’s Office first (the UK data protection regulator or the “ICO”), we would appreciate it if you gave us the opportunity to resolve any issues before contacting the ICO.

2. What data do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where an identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes 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 this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

In the provision of certain medical services we may also handle special categories of sensitive personal information including information about your physical and mental health, including any medical conditions.

3.  How is your data collected?  

We use different methods to collect data from, and about you, including:

• Direct interactions – you may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
  • subscribe to our online services;
  • contract with us to provide you with medical services;
  • create an account on our website;
  • sign-up to our newsletter or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • or give us feedback or contact us.
• Automated technologies or interactions – as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources – we may receive personal data about you from various third parties including Technical Data from analytics providers, advertising networks or search information providers (some of which may be based outside of the UK). We may also receive Contact, Financial and Transaction Data from providers of payment and technical services.
• Medical and health related services – we may receive personal data from you during the provision to you of our services and we may receive information about you from other healthcare professionals and organisations.

4.  How do we use your data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to comply with a legal obligation, perform a contract with you or 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. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Set out below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose	Type of Data	Lawful Basis
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our Terms or Privacy Policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary 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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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.

We may also process sensitive personal information to provide you with physical or mental health care, social care or treatment. We also process such data for safeguarding reasons and for legal reasons, for example, to comply with health and safety obligations or to respond to requests for information from the police or other authorities.

5. How do we use your data in marketing?   

We may like to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

6.  Do we use your data outside of the UK?   

We do not transfer your personal data outside the UK.

7.  What are our data security arrangements?  

The personal information we collect is stored in a variety of paper and electronic forms. Regardless, we have appropriate and adequate technical and administrative processes in place to make sure that all your information is kept secure. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a strict business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and the regulator of a breach where we are legally required to do so.

8.  How do we retain your data?   

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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 of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years for tax and audit purposes. In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.  What are your legal rights in relation to your data?

You have certain rights under data protection laws in relation to your personal data. You can request:

• Access to your personal data or a “data subject access request” – you can receive a copy of the personal data we hold about you.
• Correct your personal data – you can ask to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
• Erasure of your personal data – you can 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.
• Cessation of 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 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.
• Restriction on the processing of your personal data – you can ask us to suspend the processing of your personal data in certain cases including: if you want us to establish the data’s accuracy, if our use of the data is unlawful but you do not want us to erase it, if you need hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 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.
• Withdrawal of consent at any time where we are relying on consent to process your personal data – note that 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.

If you wish to exercise any of the rights set out above, please contact us on data@bwrsynergyhealth.com.

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 could 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. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.