Brinkley Physical Therapy
Privacy Policy

 

Introduction

This privacy policy tells you how Brinkley Physical Therapy Ltd (from now on referred to as ‘BPT’) uses your personal data when you visit our website, interact with us, and buy our services.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on 12th August 2020.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact ‘BPT’ about privacy below.

 

Our website and ‘BPT’ 

We are ‘BPT’ and our website address is: https://brinkleyphysicaltherapy.org 

It is available to a broad spectrum of users to inform, promote and sell the services we offer. This website is not intended for the use of children and we do not knowingly collect data relating to children.

‘BPT’ as a legal entity is:

  • Brinkley Physical Therapy LTD. Registered in England, Company No: 12776109. 
  • Registered Office: 75 Springfield Road, Chelmsford, Essex, United Kingdom, CM2 6JB
  • Head Office: The Therapy Gym, Holton Business Park, Holton St Mary, Colchester CO7 6NN

 

What personal data we collect and why we collect it

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).

Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes 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.

Profile Data includes your username and password, orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

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.

Usage Data includes information about how you use our website and services.

Tracking Data includes information we or others collect about you from cookies.

Marketing and Communications Data includes your preferences in receiving direct 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 may be derived from your personal data but is not considered personal data in law as this data does 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 page. To provide better content and service, google web analytics service which contains no personal data about you please see their privacy policy for more details.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs,  sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and/or services you’ve asked for.

 

How is your personal data collected

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 through chat or social media.

This includes personal data you provide when you:

  • make enquiries or request information be sent to you;
  • create an account on our website;
  • order our request our services;
  • ask for marketing to be sent to you;
  • engage with us on social media;
  • contact customer services; or
  • leave comments or reviews about our services.

Automated technologies or interactions. As you interact with us, including via the brinkleyphysicaltherapy.org website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:

  • Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
  • Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
  • Identity and Contact Data from data partners; and
  • Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

 

How we use your data

  • Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
  • Where you have requested/agreed, we will send you information, tips, advice and guidance via newsletter or similar medium.
  • On occasion we will send you details about additional products and services that might be useful to you and your business (this will be very occasionally and will be specific to your current infrastructure or future requirements).

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

 

Advertising, marketing and communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of 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 and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, phone, text or post. For example, you might have have our newsletter land in your inbox.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to a newsletter or as part of creating an account to purchase a service – and you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of any marketing communication.

If you have any questions about this marketing element please email us: enquiries@brinkleyphysicaltherapy.org

We also work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why, when you’ve been on the brinkleyphysicaltherapy.org website, you may see us appear somewhere again. This includes retargeting.

Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts (you know, before we risk become annoying). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance(United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

Cookies

You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used.

Cookies help us work better and provide lots of help in the background to make the process of being a our customer a lot easier. 

Other cookies collect information about how visitors use brinkleyphysicaltherapy.org, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how the brinkleyphysicaltherapy.org website works.

There are also cookies that allow us to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember personal changes you have to parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

When you use the brinkleyphysicaltherapy.org website, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account or membership and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

 

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories third parties:

  • Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
  • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
  • government, regulators and law enforcement.

We share personal data with the following specific third parties:

  • Microsoft 365 to send our direct marketing campaigns to prospective and current customers. Please visit their privacy policy.

We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

 

Payment information

‘BPT’ may use third party payment processors to process payments made for services via the Website or in person. Any online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors we never see your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.

For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

 

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

 

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

 

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

 

Where we send your data

Visitor comments may be checked through an automated spam detection service. 

 

Additional information

 

How we protect your data

We have put in place appropriate information security management systems 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.

 

What data breach procedures we have in place

We have put in place incident response procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (including but not limited to the Information Commissioners Office) of a breach where we are legally required to do so.

 

Data Retention

We will only keep 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.

We also offer a service to update you about security vulnerabilities, or essential updates relating to products you have from specific vendors. So, if you have engaged this service and unless you actively request us to delete this information, we keep it, so we can provide the service to you.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may 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.

 

Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

  • The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);
  • The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
  • The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
  • The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
  • The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
  • The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
  • Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

If you wish to exercise any of the rights set out above, please contact us (see the next section).

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.

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 may 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.

We have appointed a data privacy manager 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 us using the details in How to contact ‘BPT’ about privacy below.

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.

 

How to contact ‘BPT’ about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at enquiries@brinkleyphysicaltherapy.org and we will contact you as soon as practically possible to help fulfil your request.