We, at Widcombe Practice Ltd, treat the privacy of our visitors with the highest importance. This policy details the measures we take to preserving and safely guarding your privacy when you visit or communicate with our site(s) or personnel. Specifically it covers a detailed explanation of how we may store or otherwise use personal information about you. In particular, we want you to know that Widcombe Practice Ltd is not in the business of selling, renting or trading customers data – therefore we try our utmost hardest to ensure your data is safe and relevant measures are in place to ensure this is always the case.
1.1) We are committed to safeguarding the privacy of website users and also customers for whom we hold data on.
1.2) We are committed to allowing users as much control as possible and educating them as much as possible when interacting with our website and/or services.
1.3) In this policy “our”, “we” and “us” refers to Widcombe Practice Ltd
2) How we use your personal data
2.1) In this section we have set out:
The general categories of personal data that we may process;
The purposes for which we may process personal data; and
The legal bases of the processing
2.2) We may process “Usage Data“. This may include your IP address, geographical location, browser type, referral source, length of visit, page views and navigational paths as well as frequency of use. The source of all customer “Usage Data” is via Google Analytics. The legal basis for processing this data is our legitimate interests, namely monitoring and improving our website and service offering.
2.3) We may process “Account Data“. This may include your company details and staff details including: Full Names, Addresses, Telephone Numbers (both mobile and landline) and Genders of persons. The legal basis for this processing is our legitimate interests, namely the proper administration of your account with Widcombe Practice Ltd and to allow us to operate/work on your behalf in an efficient manner.
2.4) We may process “Enquiry Data“. This may include your company name, information on services you require, contact details (including geographic/location data) and how you heard of us. This enquiry data may be processed for the purposes of offering and recommending goods or services to yourself at an enquiry stage. The legal basis for this processing is done via consent which could be either by calling Widcombe Practice Ltd and requesting the enquiry or filling out a form on our website and requesting an enquiry. Widcombe Practice Ltd does not “cold call” or “tout” for business. Any Enquiry Data is provided to Widcombe Practice Ltd by the person(s) doing the enquiry.
2.5) We may process “Notification Data“. This is for the purposes of email notifications and/or newsletters. This notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is all persons will have consented to it in advance. This data includes your first name, last name, company and email address.
2.6) We may process “Correspondence Data“. Correspondance data may include any communication done with Widcombe Practice Ltd and can be in the form of emails, posted letters and/or notes taken whilst speaking over the phone or during meetings. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.
2.7) In addition to the specific purposes listed above we may process any data identified in this policy for compliance with legal obligations to which we are subject to. Additionally data can be processed for exercising or defending legal claims (both in court and when settled out of court) as well as maintaining insurance coverage, managing risks or obtaining professional advice.
2.8) Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3) Providing your personal data to others
3.1) We may disclose your personal data to any member of our group of companies (this means our subsidiaries, out ultimate holding company and all of its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2) 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, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3) We may disclose your Account Data and Correspondence Data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of providing an efficient service to yourself.
3.4) Financial transactions relating to Widcombe Practice Ltd and its services may be handled by our payment services providers GoCardless Ltd and Lloyds Cardnet Merchant Services . 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.
4) Retaining and Deleting Personal Data
4.1) This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2) 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.
4.3) We will retain your personal data as follows:
(a) Usage data, Notification data and Correspondence data will be retained for a minimum period of 3 years following the date it’s collected, and for a maximum period of 5 years following the date it’s collected.
(b) Account data and Enquiry data for inactive clients will be retained for a minimum period of 1 years following the date it’s collected, and for a maximum period of 3 years following the date it’s collected.
4.4) In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of Account data will be determined based on whether or not you are an active client.
(b) the period of retention of Enquiries data will be determined based on whether or not you are an active client.
4.5) Notwithstanding the other provisions of this section, 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.
5.1) We may update this policy from time to time by publishing a new version on our website.
5.2) You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3) We may notify you of changes to this policy by email.
6) Your Rights
6.1) In this Section , we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2) Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent
6.3) You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.4) You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5) In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you are no longer an active client; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6) In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7) You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8) You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9) You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10) To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11) If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.12) To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13) You may exercise any of your rights in relation to your personal data by written notice to us or by email, in addition to the other methods specified in this Section 10.
7) 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 to track abuse of our systems.
For the same reason, we may obtain information whilst you use our website by using a cookie file which is stored on the hard drive of your device you use when browsing our website. They help us to improve our site and to deliver a better and more personalised service.
They enable us to:
a) Store information about your preferences and allow us to customise our site according to your individual interests.
b) Recognise you when you return to our site and to allow functions such as “Stay Logged in” when logging in.
c) Generally, provide a better service.
8) Data Storage
At all times we work our hardest to ensure our clients’ data is stored in a safe and secure manner.
Personal data is stored in the EU whether in digital or hard copy format. Where possible we prefer to store data in the UK.
9) Our Details
9.1) This website is owned and operated by Widcombe Practice Ltd.
9.2) We are registered in England and Wales under registration number 08160772, and our registered office is at 4 Sussex Place, Claverton Street, Bath, Somerset, BA2 4LA.
9.3) Our principal place of business is at 4 Sussex Place, Claverton Street, Bath, Somerset, BA2 4LA..
9.4) You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on 01225 317 681; or
(d) by email, using email@example.com.
10) Data Protection Officer
Our data protection officer contact details are: Andrea Goodship, 01225 317 681, firstname.lastname@example.org .