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2. WHAT DATA I COLLECT ABOUT YOU AS A MEMBER Personal data means any information capable of identifying an individual. It does not include anonymised data. I may process [e.g. record, organise, structure, store, consult, use, make available, erase] certain types of personal data about you, as follows:
- Identity Data may include your first name, last name, username, title, and date of birth. If you are under 16 I require you to share with me the name of a parent or guardian, who needs also to be a member. By providing me with your data you warrant to me that you are over 13 years of age.
- Contact Data may include your address, email address and telephone numbers.
- Financial Data may include details of subscription payments to myself and of purchases made by you from myself.
- Technical Data may include your login data, internet protocol addresses, time zone setting and location, operating system and platform and other technology on devices you use to access this website.
- Profile Data may include your username and password, purchases or orders, your interests and preferences you indicate, and feedback and survey responses you make.
- Usage Data may include information about how you use this website, products and services.
- Service and Communications Data may include your preferences in receiving communications from us and our third parties and your communication preferences.
I may also process Aggregated Data from your personal data. If this does not reveal your identity, it is in itself is not personal data. An example of this is where I include your Usage Data in a review to work out the percentage of website users using a specific feature of this website. Sensitive Data: I do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, detailed information about your health, and genetic and biometric data. I do not collect any information about criminal convictions and offences. Where I am required to collect personal data by law, or under the terms of the contract between us, and you do not provide me with that data when requested, I may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide me with the requested data, I may have to cancel a product or service you have ordered but if I do, I will if possible notify you at the time.
3. HOW YOUR PERSONAL DATA IS COLLECTED Data is collected about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on this website (or otherwise) or by communicating with me by post, phone, email or otherwise, including when you:
- order products or services;
- create an account on this website;
- subscribe to a service or publications;
- request a resource or a service;
- enter a competition, prize draw, promotion or survey; or
- give feedback.
- Third parties or publicly available sources: I may receive personal data about you from various third parties and public sources as set out below
- Membership website provider SubHub based inside the EU
- Analytics and Search information providers such as Google based outside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such PayPal based inside the EU.
- Electronic Mail Service Providers such as MailChimp based outside the EU.
- Commenting and Engagement Providers such as Disqus based outside the EU
- Publishing Providers such as Issuu based outside the EU
4. HOW I USE YOUR PERSONAL DATA I will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where I need to perform the contract between us,
- Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests,
- Where I need to comply with a legal or regulatory obligation.
Consent: Generally, I do not rely on opt-in and specific consent as a legal ground for processing your personal data, other than for arranging for you to receive our newsletter. A secure record of this consent is kept by myself. You have the right to withdraw this consent at any time. Purposes for processing your personal data Set out below is a description of the ways your personal data may be used and the legal grounds on which I may process such data. Where relevant I explain what my legitimate interests are.
Please note I may process your personal data for more than one lawful ground, depending on the specific purpose for which I am using your data. Service communications You will receive service communications from me if you have requested information from me or purchased goods or services from me, and if you provided me with your accurate details. I will require your express opt-in consent before I share your personal data with any third party for service purposes. You can ask me or third parties to stop sending you messages at any time by following the opt-out links on any message sent to you or by emailing me at firstname.lastname@example.org at any time. Where you opt-out of receiving my service communications, this will not apply to personal data provided to me as a result of a product/service purchase, warranty registration, product/service experience or other transactions. Change of purpose: I will only use your personal data for the purposes for which I collected it unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If I need to use your personal data for a purpose unrelated to the purpose for which I collected the data, I will notify you and I will explain the legal ground of processing.Please note I may process your personal data without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA I may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Service providers who provide IT and system administration services, especially subhub.com, the host organisation for atopicskindisease.com.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom I sell, transfer, or merge parts of my service.
- I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.
6. INTERNATIONAL TRANSFERS As countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, European law prohibits transfer of personal data outside of the EEA unless the transfer meets certain criteria. Some of the third parties service providers are based outside the European Economic Area (EEA) and processing of your personal data may therefore involve a transfer of data outside the EEA. Whenever your personal data is transferred out of the EEA, to ensure a similar degree of security of data, at least one of the following safeguards is implemented:
- Transfer of your personal data only to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where certain service providers are used, specific contracts or codes of conduct or certification mechanisms approved by the European Commission give personal data the same protection it has in Europe; or
- Where providers are based in the United States, transfer data to them if they are part of the EU-US Privacy Shield [which requires them to provide similar protection to personal data shared between the Europe and the US].
If none of the above safeguards is available, your explicit consent to the specific transfer may be requested, You will have the right to withdraw this consent at any time.
7. DATA SECURITY Appropriate security measures are in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, access to your personal data is limited to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on my instructions. They are subject to a duty of confidentiality. Procedures are in place to deal with any suspected personal data breach and I will notify you and any applicable regulator of a breach where I am legally required to do so.
8. DATA RETENTION I will only retain your personal data for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements. By law I have to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes. In some circumstances you can ask me to delete your data: see below for further information. In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under Data Protection Law in relation to your personal data. These include the right to:
- 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.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email me at email@example.com You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances. I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response. I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
10. THIRD-PARTY LINKS 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. I do not control these third-party websites and are not responsible for their privacy statements. When you leave this website, I encourage you to read the privacy notice of every website you visit.
12. NEED TO CLARIFY OR DETAIL THIS POLICY If there is any aspect of this policy that needs clarification or further detail, please contact me at DrB@atopicskindisease,com
Dr Christopher Bridgett