COOKIES & PRIVACY POLICY

This privacy notice explains how re-enhance Ltd uses your personal data and your legal rights in respect of our use of your data. It applies to our clients and prospective clients and those visiting our website.

For the purpose of this privacy notice, data protection legislation includes the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulation 2003.

It is important that you read this privacy notice together with any other privacy notice and terms and conditions we may provide on specific occasions when we are collecting or processing personal data about you so that you are always fully informed of how and why we are using your data.

Re-enhance is the data controller of your personal data (collectively referred to as Re- Enhance. “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, how we use your data or wish to exercise your legal rights, please contact us using the details set out below.

Re-enhance Medical & Dental Clinic
Progress House
17 Cecil Road
Hale
WA15 9NZ
Info@re-enhance.com

If you are dissatisfied with the way in which we have processed your data, you have the right to make a complaint to the UK regulator, the Information Commissioner’s Office (ICO) (ico.org.uk). We would always ask that you contact us first.

We may update this privacy notice from time to time. This version was last updated in February 2022 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, and retain different categories of personal data about you:

  • Name, marital status, date of birth and gender.
  • Address (shipping, billing and home), email address, phone number, user name, IP address and social media identifiers.
  • Bank and credit card details and transaction history.
  • Treatment records including information about the treatment you wish to (or have) received from us.
  • Treatment records may include before and after photographs of the area of treatment. This information could include health data which is also referred to as special category data and therefore requires us to take extra steps to ensure it is adequately protected.
  • Some of our clinics have CCTV. There will always be warning signs where CCTV is in
    operation.
  • We may also record telephone calls, but will let you know when we are doing this.
  • Your marketing and communication preferences. This may also include information about interest in specific products and treatments so that we can send you marketing campaigns about products we believe you will be interested in.
  • Information about how you use our website.

Our lawful basis for processing your data
Our lawful basis for processing your data when making an enquiry or when purchasing a product or treatment from us is “contract”. There may also be situations where it may be in our legitimate interest to retain your data. This is likely to be restricted to complaints management, profit protection and health and safety and the use of CCTV and call recording.

In almost all situations the data we hold would have been provided by you. For example, when you make an enquiry, purchase a product or service, join our marketing list, or interact with us in some other way. We may also receive data from your healthcare professional, but this would only be disclosed to us with your explicit consent.

We will only use your personal data when the law allows us to and in accordance with this privacy notice. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you for the provision of a product or service;
  • 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;
  • marketing Activities; and
  • to respond to any complaint and help us to establish, exercise or defend legal claims.

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 or text message and the use of non-essential cookies and similar tracking technologies. You have the right to withdraw consent to marketing at any time by contacting us.

How we use your data
Health data
In light of the services which we provide to our clients, it may be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with a treatment.

Marketing
We may send you marketing by email, sms, post or telephone. You will have either been given the opportunity to opt-out from receiving marketing at the time we first captured your contact information, or you may have given your consent. You can change your preferences at any time, for example the channel used to hear from us or opt-out all together. All marketing communications include an opt-out, or you can contact us by email and ask us to unsubscribe you (info@re-enhance.com ).

Service communications
We may contact you by email, SMS, phone or post to remind you about an upcoming treatment or other important matter. We also find it helpful to hear about client treatment experiences and may send you a survey to give you the opportunity to share this with us. You can opt-out from receiving surveys at any time.

Disclosing your personal data
Like all businesses, there are certain situations where we may be required to disclose your personal data to a third party. This is likely to be limited to the following:

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of
    processing activities in certain circumstances.

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 third-party 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.

Where do we hold your data
We do not transfer your personal data outside the European Economic Area (EEA).

Data security
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 business need to know. They will only process your personal data on our strict 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 any applicable regulator of a breach where we are legally required to do so.

How long do we retain your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements. In most situations, we are unlikely to hold your data for more than 7 years after your last treatment. Where you make an enquiry but never progress to a treatment we would ordinarily delete your data 2 years after our last interaction with you.

Your legal rights
You have the right to:

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.

Request erasure of your personal data. 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. It is important to understand that the right to erasure is often not an absolute right.

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 where we are relying on consent 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.

If you wish to exercise any of the rights set out above, please contact us at info@re-enhance.com

No fee usually required
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.

What we may need from you
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.

How long we have to respond
We try to respond to all subject access requests within one month. Occasionally it may take us longer than a month if your request is particularly complex. If this is case, we will notify you and keep you updated.

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