COOKIE AND PRIVACY POLICY

Eyano Medical & Ancillary Services Ltd is committed to protecting and respecting  your privacy. 

We respect your privacy, and we are committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when  you visit our website (regardless of where you visit it from) and tell you about your  privacy rights and how the law protects you.   This policy has been prepared to reflect the changes introduced by the Data  Protection Act 2018 (“DPA”) and the General Data Protection Regulation (“GDPR”).  In this privacy policy we seek to abide by the letter and spirit of the guidelines laid out  by the ICO on their webpage on the ‘Right to be Informed’. 

[This privacy policy is provided in a layered format so you can click through to the  specific areas set out below. Alternatively, you can download a pdf version of the  policy here: https://eyanomedical.co.uk . Please also use the Glossary to understand  the meaning of some of the terms used in this privacy policy. 

1. IMPORTANT INFORMATION AND WHO WE ARE 

2. THE DATA WE COLLECT ABOUT YOU 

3. HOW IS YOUR PERSONAL DATA COLLECTED 

4. HOW WE USE YOUR PERSONAL DATA 

5. DISCLOSURES OF YOUR PERSONAL DATA 

6. INTERNATIONAL TRANSFERS 

7. DATA SECURITY 

8. DATA RETENTION 

9. YOUR LEGAL RIGHTS 

10. GLOSSARY

PURPOSE OF THIS PRIVACY POLICY 

This privacy policy aims to give you information on how we collect and process your  personal data through your use of this website, including any data you may provide  through this website when you create an account with us or purchase our Services. It is important that you read this privacy policy together with any other privacy policy  or fair processing policy we may provide on specific occasions when we are  collecting or processing personal data about you so that you are fully aware of how  and why we are using your data. This privacy policy supplements other notices and  privacy policies and is not intended to override them. 

CONTROLLER 

Eyano Medical & Ancillary Services Ltd is the data controller and responsible for your  personal data (collectively referred to as "we", "us" or "our" in this privacy policy). We  may also act as a data processor if we subsequently deliver our services to you.  We have appointed a data protection officer (DPO) who is responsible for overseeing  questions in relation to this privacy policy. If you have any questions about this  privacy policy, including any requests to exercise your legal rights, please contact the  DPO using the details set out below. 

CONTACT DETAILS 

If you have any questions about this privacy policy or our privacy practices, please  contact our DPO in the following ways: Full name of legal entity: Eyano Medical & Ancillary Care Services Ltd Email address: contactus@eyanomedical.co.uk 

You have the right to make a complaint at any time to the Information  Commissioner's Office (ICO), the UK supervisory authority for data protection issues  (www.ico.org.uk). We would, however, appreciate the chance to deal with your  concerns before you approach the ICO so please contact us in the first instance.

The Information Commissioner can be contacted at: 

Wycliffe House , Water Lane , Wilmslow , Cheshire , SK9 5AF Or at https://ico.org.uk/concerns/ 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 

We keep our privacy policy under regular review. This version was last updated on  11/11/20.  

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

Personal data, or personal information, 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, 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, your home address, email address and  telephone numbers. 

• Health Data includes any information about your health including your medical  history and/or current health status including but not limited to data regarding test  results, diagnoses and medications.  

• Financial Data includes bank account and payment card details. 

• Transaction Data includes details about payments to and from you and other  details of Services and Subscription Packages 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. 

We may collect Special Categories of Personal Data about you. This includes  details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual  orientation, information about your health, and genetic and biometric data). We do  not collect any information about criminal convictions and offences. 

IF YOU FAIL TO PROVIDE PERSONAL DATA 

Where we need to collect personal data by law or under our terms of use Eyano Policy, and you fail to provide that data when requested, we may not be able to  perform the Service. In this case, we may have to cancel your Booking for Services  with us, but we will notify you if this is the case at the time.

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

Direct interactions. You may give us your Identity, Contact and Financial Data  by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you: 

• applying for our Services; 

• create an account on our website; 

• subscribe to one of our Subscription Packages; 

• request marketing to be sent to you; 

• 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 server logs and other similar  technologies.  

• Third parties or publicly available sources. We may receive personal data  about you from various third parties as set out below: 

Identity Data and Health Data from the following parties: 

(a) your GP; and  (b) other healthcare specialists and consultants who have provided you  with any health care services and/or treatment with the United  Kingdom or, if relevant, overseas. 

The lawful bases for processing personal data are set out in Article 6 of the General  Data Protection Regulation (GDPR). We may process your personal data on more  than one lawful ground depending on the specific purpose for which we are using  your data. Please contact us if you need details about the specific legal ground we  are relying on to process your personal data where more than one ground has been  set out below. At least one of these must apply whenever we process personal data:  

• Consent:  you have given clear consent for us to process your personal data  for a specific purpose.  

• Contract:  the processing is necessary for a contract we have with you (for  example, to process and deliver healthcare services to you and to manage  our relationship with you), or because you have asked us to take specific  steps before entering into a contract. 

• Legal obligation:  the processing is necessary for us to comply with a legal  or regulatory obligation (not including contractual obligations). 

• Vital interests:  the processing is necessary to protect someone’s life. 

• Legitimate interests: the processing is necessary for our legitimate interests  (for example to administer and maintain our website) or the legitimate  interests of a third party unless there is a good reason to protect your  personal data which overrides those legitimate interests. We make sure we  consider and balance any potential impact on you (both positive and  negative) and your rights before we process your personal data for our  legitimate interests. We do not use your personal data for activities where our  interests are overridden by the impact on you (unless we have your consent  or are otherwise required or permitted to by law).  

We rely on the following legitimate interests when processing your personal  data: 

o To manage our business and comply with our obligations to our  patients, staff and suppliers 

o To protect our proprietary and commercially sensitive information  o To administer and maintain our website.

We also need to satisfy specific conditions for using your health data. We rely upon  the following ground in this regard: 

• Express Consent: you expressly consent to the processing of data  concerning your health to allow us to deliver our services. OR  

• Healthcare provision: the processing of data concerning your health is  necessary for us to allow you to book an appointment with a health care  provider who can then provide you with a medical diagnosis and/or healthcare  treatment.  

Click here to find out more on the Information Commissioner’s Office website about  the types of lawful basis that we will rely on to process your personal data. 

Generally, we do not rely on consent as a legal basis for processing your personal  data other than as described below. However, where we do ask for your consent (for  example in processing data relating to your health) we will do so in order to comply  with the principle that any processing must be lawful, fair and transparent.  

MARKETING 

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

PROMOTIONAL OFFERS FROM US 

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 (we call  this marketing). 

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. 

THIRD-PARTY MARKETING 

We will get your express opt-in consent before we share your personal data with any  third party for marketing purposes. 

OPTING OUT 

You can ask us or third parties to stop sending you marketing messages at any time  by logging into the website and checking or unchecking relevant boxes to adjust your  marketing preferences. Where you opt out of receiving these marketing messages, this will not apply to  personal data provided to us as a result of the Services or Subscription Packages  that you have purchased from us. 

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 you wish to get an explanation as to how the  processing for the new purpose is compatible with the original purpose, please  contact us at contactus@eyanomedical.co.uk. 

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 have to share your personal data with the parties below in order to provide  our services to you. We require all third parties to respect the security of your  personal data and to treat it in accordance with the law, and when they are  processing personal data on our behalf 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 and in accordance with the law. Examples of our third parties include:  

• Third parties who you authorise to provide services to you. 

• Sub-contractors for the performance of any contract we enter into with them  or you. 

• Service providers acting as processors who provide IT and system  administration services. 

• Professional advisers including lawyers, bankers, auditors and insurers based  who provide consultancy, banking, legal, insurance and accounting services. 

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

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 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 WILL YOU USE MY PERSONAL DATA FOR? 

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. 

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information. 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.

Under certain circumstances, you have rights under data protection laws in relation to  your personal data. Please click on the links below to find out more about these  rights: 

Request access to your personal data]. 

Request correction of your personal data]. 

Request erasure of your personal data]. 

Object to processing of your personal data]. 

Request restriction of processing your personal data]. 

Request transfer of your personal data]. 

Right to withdraw consent]. 

If you wish to exercise any of the rights set out above, please contact us at  contactus@eyanomedical.co.uk 

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 could 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. 

TIME LIMIT TO RESPOND 

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  a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS 

You have the right to: 

9.1 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. 

9.2 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. 

9.3 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. 

9.4 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. 

9.5 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: 

• If you want us to establish the data's accuracy. 

• Where our use of the data is unlawful, but you do not want us to erase it.

• 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. 

• You have objected to our use of your data, but we need to verify whether  we have overriding legitimate grounds to use it. 

9.6 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. 

9.7 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.

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